HomeMy WebLinkAbout1303 RemboldIn Re: Charles Rembold
File Docket:
X -ref:
Date Decided:
Date Mailed:
Before: Louis W. Fryman, Chair
John J. Bolger, Vice Chair
Daneen E. Reese
Frank M. Brown
Donald M. McCurdy
Michael Healey
Paul M. Henry
01- 079 -C2
Order No. 1303
12/1/03
12/15/03
This is a final adjudication of the State Ethics Commission.
Procedurally, the Investigative Division of the State Ethics Commission conducted an
investigation regarding a possible violation of the Public Official and Employee Ethics Act, Act
9 of 1989, P.L. 26, 65 P.S. §§ 401 et seq., as codified by Act 93 of 1998, Chapter 11, 65
Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its
investi9ation, the Investigative Division served upon Respondent written notice of the specific
allegation(s). Upon completion of its investi9ation the Investigative Division issued and
served upon Respondent a Findings Report identified as an "Investigative Complaint." An
Answer was filed and a hearing was waived. The record is complete. A Consent Agreement
and Stipulation of Findings were submitted by the parties to the Commission for consideration.
The Stipulation of Findings is quoted as the Findings in this Order. The Consent Agreement
was subsequently approved.
Effective December 15, 1998, Act 9 of 1989 was repealed and replaced by Chapter 11
of Act 93 of 1998, 65 Pa.C.S. § 1101 et seq., which essentially repeats Act 9 of 1989 and
provides for the completion of pending matters under Act 93 of 1998.
This adjudication of the State Ethics Commission is issued under Act 93 of 1998 and
will be made available as a public document thirty days after the mailing date noted above.
However, reconsideration may be requested. Any reconsideration request must be received at
this Commission within thirty days of the mailing date and must include a detailed explanation
of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code §
21.29(b). A request for reconsideration will not affect the finality of this adjudication but will
defer its public release pending action on the request by the Commission.
The files in this case will remain confidential in accordance with Chapter 11 of Act 93 of
1998. Any person who violates confidentiality of the Ethics Act is guilty of a misdemeanor
subject to a fine of not more than $1,000 or imprisonment for not more than one year.
Confidentiality does not preclude discussing this case with an attorney at law.
Rembold 01- 079 -C2
Page 2
I. ALLEGATION:
That Charles Rembold, a public official /public employee, in his capacity as the
Superintendent for the West Greene School District, Greene County, violated Sections
1103(a), 1103(f) and 1104(a) of the Public Official and Employee Ethics Law when he used
the authority of his position for a private pecuniary benefit of himself and /or a business with
which he is associated; when he participated in discussions and actions of the West Greene
School District resulting in the district's implementation of the PULSE program (People
Utilizing Leadership Skills Effectively), and the district's acquisition of grant funds to pay for
the PULSE program at a time when he was employed by and serving as a director for King's
Bridge Inc., the entity which developed and owned the copyright for the PULSE program and
which entity would receive payment from the district for use of the PULSE program; when the
contract with King's Bridge Inc., was entered into without an open and public process; when he
participated in the administration of the district's contract /subcontract with King's Bridge Inc.;
when he submitted and received duplicate expense reimbursements from the West Greene
School District, Southern Columbia School District and King's Bridge Inc. for the same
expenses related to King's Bridge business; when he conducted King's Bridge business on
district time using school district facilities, equipment and supplies; when he secured grant
funding for a technology coordinator position that he developed for his son and for which his
son was ultimately hired to fill; and when he failed to file Statements of Financial Interests for
the 1997, 1998, 1999 and 2000 calendar years.
II. FINDINGS:
1. Charles P. Rembold was employed as the Superintendent of the West Greene School
District (WGSD) from July 1, 1993, until August 20, 2001.
a. Rembold resigned to accept a position as the superintendent of the Jefferson -
Morgan School District.
1. Rembold is currently employed as Superintendent of the Jefferson -
Morgan School District.
2. Rembold's duties and responsibilities as superintendent of WGSD include:
a. Administration of the schools under the direction of the board of directors. The
Superintendent shall be the Chief Executive Officer of the District; shall be
responsible for:
1. recommending the employment of all employees and directing and
assigning teachers and other employees of the schools under his
supervision.
2. organizing, supervising and arranging the administrative and supervisory
staff;
3. suggesting regulations, rules and procedures deemed necessary for the
efficient and proper operation of the District;
4. performing all duties incident to the office of the Superintendent as set
forth in the Public School Code;
5. such other duties as may be prescribed by the Board.
b. The superintendent agrees to devote his full time, attention, energies, skills and
labor to his employment as Superintendent of the District during the term of this
Agreement provided however; that he may undertake consultative work,
Rembold 01- 079 -C2
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speaking engagements, writing, lecturing or other professional duties provided
the Board is informed and does not direct him not to discontinue such activities.
c. Rembold's employment contract included compensation days as follows:
1. Vacation: Twenty (20) working days of vacation from July 1 through
June 30. All vacation time shall fit in with school needs and may be
taken intermittently.
2. Holidays: As stated in the school calendar.
3. Personal Days: Three (3) personal leave days per year. Personal leave
days may accumulate to five (5) days. A payment of $50 may be made
for each day not utilized or not taken.
4. Sick Leave: Twelve (12) sick leave days per year cumulative, with no
limitation. An additional seventy -five (75) sick days will be allocated,
subject to restrictions concerning severance payments.
3. Rembold received a superintendent's certificate from the Pennsylvania Department of
Education, and his educational background includes degrees from:
a. Ph.D., Education Administration, Walden University, 2002.
b. Advanced Masters Program, Administration, Supervision, Curriculum,
University of Virginia, 1972.
c. M.Ed., Counseling, University of Virginia, 1970.
d. B.S., Mathematics, California University of Pennsylvania, 1968.
4. Prior to being employed by Pennsylvania school districts, Rembold held various
educational positions in the Commonwealth of Virginia.
The following findings related to the development of the PULSE program, King's
Bridge Inc., and their involvement with the PULSAR program in Virginia, and
Mainstream Counseling, Inc., Huntingdon, PA
5. Rembold has been involved with King's Bridge Inc., a Virginia corporation since at least
July 1983.
a. Rembold served as an initial director of the corporation, was formally listed as a
director on the corporation papers on file with the Virginia Corporations
Commission until 2001 and served as a consultant/ contractor providing training
programs, research and other services.
6. King's Bridge Inc., offers training programs for schools, businesses, government, and
police.
a. One of the programs developed by King's Bridge, Incorporated for school
district focused on at -risk students.
b. The PULSE program is the cornerstone of the training programs offered by
King's Bridge.
c. King's Bridge Inc. holds the copyright for the PULSE Program.
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7. King's Bridge Inc., filed articles of incorporation with the Virginia State Corporation
Commission on July 28, 1983, which identified Rembold as one of two shareholders.
a. The other shareholder was identified as R. Edgar Thacker, 907 West Poplar
Road, Fairfax, VA 22170.
8. Corporations registered in the Commonwealth of Virginia are required to file annual
reports listing current corporate officers, directors and disclosing changes in officers
and /or directors.
a. R. Edgar Thacker, corporate secretary, has annually completed and submitted
reports on behalf of King's Bridge Inc., since at least 1993.
9. On March 8, 1993, R. Edgar Thacker filed an annual report with the Virginia
Corporation Commission that included corporate officers and directors as follows:
a. Charles P. Rembold, President /Director
R. E. Edgar Thacker, Secretary /Director
Carla Watson, Director
Steven Wilcox, Director
10. Rembold was formally listed as a president /corporate director in annual reports filed on
March 28, 1994, March 14, 1995, March 20, 1996, March 19, 1997, August 7, 1998,
July 15, 1999, and July 17, 2000.
11. By way of correspondence dated February 17, 1993, from Rembold to Thacker,
Rembold resigned as president and stockholder in King's Bridge Inc., Rembold's letter
noted the following:
a. Rembold informed that he believes in the program; however, the Staunton
"PULSAR" experience dampened his charges.
b. Rembold is applying for a superintendent's position in Pennsylvania and will
carry the PULSE concepts and beliefs there.
c. Rembold asserts that he would be willing to assist King's Bridge with future
trainings.
12. By way of correspondence dated August 5, 2000, from Rembold to Thacker, Rembold
reiterated his desire to be removed as president and stockholder in King's Bridge Inc.,
as follows:
"I appreciate the board not wanting me removed; however, I think it in the best
interest just to continue my role as researcher and working for expenses. Please take
care of the details. I was surprised after all of this time that I was still listed."
13. Two annual reports were filed in 2001 by Thacker on behalf of King's Bridge that noted
changes in the directors for King's Bridge Inc.
a. A report filed on June 1, 2001, lists the removal of Charles P. Rembold and
Michael Stephen Wilcox as corporate officers and /or directors.
b. A report filed on July 10, 2001, lists R.E. Thacker as President /Director and
Brenda Spratt as Director.
c. Prior to May 15, 2001, the only changes made to King's Bridge Inc.'s
officers /directors was the addition of Brenda Spratt on March 28, 1994, and the
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deletion of Carla Watson as a director on March 19, 1997.
14. Beginning in or about 1991, PULSAR, Inc. offered a training program package under
the program name PULSAR to public entities in Virginia.
a. The PULSE concept was developed by Rembold, Thacker, and Wilcox while all
three were employed in the Fairfax County, Virginia, school system during the
early 1980's.
b. PULSE is an acronym for "People Utilizing Leadership Skills Effectively."
15. Rembold introduced the King's Bridge /PULSE concept to Robert E. Lee High School,
Staunton, VA, in the late 1980's.
a. Rembold was the principal at the Robert E. Lee High School at that time.
16. The PULSAR program was presented to the Staunton Cadre at an action planning
session conducted in Wintergreen Resort in VA.
a. Those attending the presentation from Staunton included Chief of Police G.L.
"Butch" Wells, Judy Shuey, Eddie Dick, Charles Rembold, and others from the
Staunton Drug Task Force.
b. The program proposed by Rembold was actually titled PULSAR, which was
similar conceptually to the PULSE program developed by King's Bridge.
c. Grant money was obtained from the Commonwealth of Virginia during the fiscal
years 1990 -91 and 1991 -92 to fund the program.
1. Expenditures were handled under the supervision of Wells.
17. Grant funding was awarded to the City of Staunton from the Governor's Signature Program,
which encouraged Virginia communities to implement the PULSAR program.
a. Funds were secured for the following purposes:
1. To hire an executive director and secretary for PULSAR, Inc.;
2. To develop a videotape of the PULSAR program;
3. To develop a professional PULSAR training manual;
4. To conduct an evaluation of the benefits of the PULSAR program;
5. To conduct and perform five presentations to various communities in the
Commonwealth of Virginia.
b. A $100,000 startup grant was received from the Virginia Governor's
Commission on Drug & Alcohol Use for the 1990 -1991 and 1991 -1992 fiscal
years.
c. The purpose of the grant was to train communities, including schools, police
departments, children and youth agencies, the Virginia Cadre, and any
interested citizen in the PULSAR model, so that the model could be
implemented by various community groups.
d. Grant expenditures were handled through the Staunton Police Department with
Wells, Rembold, and police corporal Eddie Dick conducting PULSAR facilitator
trainings at locations selected by the state.
e. As consultants /trainers, Rembold, Wells, and Dick received $200.00 per day
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compensation plus travel and operating expenses.
18. PULSAR, Inc. was incorporated with the Virginia State Corporation Commission on
April 15, 1991, after the initial grant was received.
a. Original incorporators were Police Chief G.L. Wells, Charles Rembold, and
Edgar Thacker, both of King's Bridge.
b. The stated purpose of the corporation was to educate the public, students,
educators and law enforcement officials and to increase their awareness
respecting the causes of, the dangers and problems of, and the method of
dealing with students at -risk, including but not limited to low self- esteem,
students suffering from depression, truant students and juvenile offenders.
19. Annual reports filed with the Virginia State Corporation Commonwealth confirm
Thacker and Brenda R. Spratt's involvement as corporate officers and directors of
PULSAR until March 30, 1994.
a. Thacker and Spratt resigned as corporate officers and directors of PULSAR
effective March 30, 1994.
1. Thacker was replaced as chairman by Walter E. Brown, a Staunton
Police Official.
b. Rembold was not listed as a corporate officer or director on any annual reports
filed by PULSAR.
20. In or about 1994, a philosophical difference occurred among the PULSAR directors.
21. One of the issues existing between the parties focused on the equitable pay to be
made to trainers, specifically with respect to any lost per diem wages of that individual,
including the loss of vacation /personal leave days that may have to be used in order to
conduct the PULSAR training programs.
a. According to Rembold, other issues included the independence of the PULSAR
training staff, the employment of Claire Brown as a PULSAR trainer and the
lack of understanding of the program by Walter Brown.
22. Additionally, Michael Steven Wilcox, one of the PULSE originators and a listed director
of King's Bridge Inc. suggested to Walter Brown that PULSAR could serve as a "pass
through" of funds for King's Bridge.
a. Wilcox's idea of increasing revenues for King's Bridge was that PULSAR keep
10% of the consulting revenues generated while turning over or "passing
through" the balance of the funds to King's Bridge.
b. Brown objected to this arrangement.
c. PULSAR continues to operate primarily in the Commonwealth of Virginia
without the involvement of Rembold, Wilcox, Thacker, or Spratt.
d. Rembold does not contest that Brown testified as to the foregoing. He does,
however, assert that he was unaware of this conversation.
23. Following the split from the PULSAR group, King's Bridge continued to operate and
provide the PULSE program.
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24. In November of 1993, Arthur Waleski became employed as an Assistant High School
Principal by the Huntingdon Area School District, Huntingdon, PA.
a. Waleski was familiar with Rembold, Wilcox, and Thacker.
1. Rembold, Wilcox, and Thacker all had been previously employed in the
Fairfax County, Virginia, school system.
2. Waleski was familiar with the PULSAR program as a result of serving as
Assistant Principal at R.E. Lee High School in Staunton, VA.
3. Waleski worked under the supervision of Rembold at Robert E. Lee
High School, Staunton, VA.
25. The Huntingdon Area School District, utilized the services of Mainstream Counseling
to perform drug and alcohol counseling services while Waleski served as Assistant
Principal.
a. Mainstream Counseling is an entity based in Huntingdon, PA that provides
substance abuse prevention services.
26. Lonnie Woomer is the owner of Mainstream Counseling, 1001 Washington Street,
Huntingdon, PA 16652, (814) 643 -1114.
27. Waleski introduced Woomer to the PULSE program concept in 1994.
a. Waleski was interested in setting up a PULSE program at Huntingdon Area
School District.
b. Waleski arranged for Woomer to attend a youth PULSE retreat sponsored by
West Greene School District at Camp Harmony, P.O. Box 158, 1414 Plank
Road, Hooversville, PA 15936, around the spring of 1995.
c. At this training, Woomer was introduced to Rembold, Wilcox, and Thacker.
d. From the spring of 1995 through 2001, the time period Woomer was associated
with King's Bridge, Woomer testified and was under the impression that
Rembold, Wilcox, and Thacker were the principals of King's Bridge.
28. After learning of Woomer's /Mainstream Counseling's drug and alcohol services,
Rembold wanted Mainstream to be used for programs at the West Greene School
District.
29. During 2000 and 2001, King's Bridge Inc. utilized Mainstream Counseling in relation to
King's Bridge Inc.'s provision of services to WGSD.
a. King's Bridge asked Mainstream Counseling if it would be listed at the top of the
PULSE organizational chart.
1. The chart depicted Mainstream Counseling as receiving funding through
grants and contracting with King's Bridge for program marketing,
development, management, implementation, and evaluation.
2. King's Bridge, in turn, would contract with the PULSE core training staff,
as independent contractors, which included Rembold, Wilcox, Thacker,
Waleski, and Woomer, WGSD Principal, Brian Jackson, and WGSD
employee, Linda Jones.
Rembold 01- 079 -C2
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b. Mainstream would be used as the entity to contract with local entities and then
contract with King's Bridge to provide services.
30. Woomer attended a PULSE retreat sponsored by King's Bridge for the Huntingdon
Area and the West Greene School District held at Camp Harmony during October or
November 1999.
a. During this retreat, a meeting was held which was attended by Rembold,
Thacker, and Wilcox, Waleski, and Woomer.
b. The purpose of this meeting was to discuss Mainstream Counseling's affiliation
with King's Bridge Inc.
1. Woomer was under the impression that Rembold, Wilcox, and Thacker
were acting on behalf of King's Bridge Inc.
31. During the meeting, Rembold it was suggested that using the services of Mainstream
Counseling be utilized at the Southern Columbia Area and West Greene School
Districts.
a. Rembold was superintendent at West Greene at the time.
b. Wilcox was superintendent at Southern Columbia Area School District at the
time.
32. Woomer informed Rembold, Wilcox, and Thacker that she was willing to enter into a
business relationship with King's Bridge Inc., to officially provide these services,
provided two (2) conditions were made.
a. Woomer insisted on a signed contract between Mainstream Counseling and
King's Bridge Inc.
b. Woomer insisted that both Rembold and Wilcox not be on the board of directors
and not have any ownership interest in or names on any paperwork for King's
Bridge Inc.
c. Woomer had reservations and concerns with Rembold and Wilcox being
affiliated with King's Bridge and then contracting with school districts where they
serve as superintendent.
33. Woomer reached an oral agreement relative to these conditions with Rembold, Wilcox,
and Thacker during this meeting.
a. Rembold neither denied nor admitted having ownership or directorship interest
in King's Bridge Inc., during this meeting (fall of 1999).
b. Both Rembold and Wilcox agreed to have their names removed as directors of
King's Bridge.
34. On December 1, 1999, Woomer d /b /a Mainstream Counseling, Inc. entered into a one -
year professional services contract with King's Bridge Inc. effective January 1, 2000.
a. King's Bridge was identified as the consulting company for PULSE services.
b. The agreement stated the terms and conditions which King's Bridge
(consultant) would provide consulting services to Mainstream Counseling
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Agency.
35. Contract terms between King's Bridge and Mainstream included the following:
a. King's Bridge agrees to provide consulting services to Mainstream for program
development specifically related to prevention and intervention programs as
necessary.
b. King's Bridge agreed to plan, organize, and conduct trainer of trainer adult
PULSE seminars.
c. King's Bridge agreed to provide organization and execution of the facilitation of
PULSE student retreats.
d. Supervision and control of the performance of King's Bridge services shall be
under the direct control of Kings Bridge.
e. The time, manner, and amounts of services shall be under the control of
Mainstream, and Mainstream shall provide a suitable work environment for the
performance of consulting services.
f. The contract was signed by Edgar Thacker on behalf of King's Bridge Inc. and
Lonnie Woomer as Mainstream Counseling.
36. Compensation to be provided to King's Bridge by Mainstream as part of this agreement
was stated as follows:
a. Compensation will be provided for consulting services according to individual
services provided.
1. Due to varied fees and services involved, no pre- determined standard of
reimbursement will be designated.
b. King's Bridge would be compensated after submitting a detailed invoice for
specific services to Mainstream but not before Mainstream Counseling received
reimbursement for the services from their payor source.
c. No set fees were ever set as part of King's Bridge and Mainstream's
agreement.
37. The agreement between Mainstream and King's Bridge did not require Mainstream to
provide any services, other than to compensate King's Bridge for services provided on
behalf of Mainstream.
a. Mainstream essentially served as a billing agent for services King's Bridge
provided to school districts.
b. Mainstream was paid a flat fee of five (5 %) percent of any billings made to
school district's for services provided by King's Bridge.
c. This arrangement was used primarily with the West Greene School District and
on one occasion with the Southern Columbia Area.
1. The arrangement was only used at Southern Columbia School District
after school board members began to question Wilcox's affiliation with
King's Bridge Inc.
38. Woomer entered into a separate agreement with King's Bridge Inc., on December 9,
1999, to provide consulting services separate from the King's Bridge Inc. contract with
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Mainstream Counseling.
39. On at least four (4) occasions between January 2000 and February 2001, Rembold
advised Woomer that he and Wilcox resigned from King's Bridge records as agreed
upon.
a. Rembold and Wilcox remained listed as directors for King's Bridge until June 1,
2001.
40. Woomer had discussions with Rembold regarding the PULSE program and related
drug and alcohol issues between January 2000 and January 2001.
a. These contacts were related to the West Greene Area School District's PULSE
program as well as other PULSE activities involving other drug and alcohol
activities.
b. Woomer had similar dealings with King's Bridge Director Wilcox regarding
Southern Columbia.
41. King's Bridge was an inactive company between 1996 and 1999 when Rembold,
Wilcox, and Thacker developed the PULSE program for use in Pennsylvania school
districts where Rembold and Wilcox were employed.
a. The PULSE program was actively marketed by Rembold and Wilcox after they
became established as school district superintendents in West Greene and
Southern Columbia.
The following findings relate to allegations that Rembold used his position as
Superintendent at West Greene Area School District to obtain grant money for
PULSEIKing's Bridge programs
42. Rembold, as superintendent of the West Greene Area School District (WGSD),
oversaw the day -to -day operation of the district's schools, teachers, and administrators;
preparing board meeting topic and agenda items; and identifying, applying for and
securing grant funding.
a. Rembold utilized a variety of sources to identify grant resources including
websites, grant writers, the PA Department of Education, and word of mouth.
b. Rembold was not required to obtain board approval to seek grant funding on
behalf of the district.
1. Rembold, as superintendent, would generally advise the board of grant
funding received and its designated uses.
43. Beginning with his hiring as WGSD superintendent in July 1993, Rembold, in his
capacity as superintendent participated in the development of PULSE program for the
WGSD.
a. As superintendent, Rembold oversaw the preparation and submission of grant
applications which identified the PULSE program and providers/ contractors as
King's Bridge and /or Mainstream Counseling.
44. WGSD did not have a PULSE program prior to Rembold's tenure as superintendent.
45. The WGSD Board was provided with information by Rembold on the PULSE program
and grant funding for the program.
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a. The board was supportive of the district's involvement in the PULSE program.
b. The board permitted Rembold and /or district staff to apply for grants.
c. The board played no role in identifying or applying for grant funding.
d. The board informally accepted grant funding obtained by Rembold.
46. The district's PULSE program included training for teachers, administrators and staff,
educational services and PULSE retreats for students.
a. Program funding came from state and federal grants and in -kind contributions
by the district.
b. Rembold had oversight over all aspects of the district's PULSE program.
47. Minutes from the WGSD School Board of Directors include the following discussions
encompassing information furnished to the board on the district's PULSE program and
related funding:
July 22 1993: The school board adopted the Student Services Module which included
implementation of the PULSE program.
November 17, 1994: Rembold reported on the PULSE retreat.
December 9 1994: Rembold gave his time to Linda Jones who brought a student to
give a presentation on the PULSE program and PULSE retreat.
February 23, 1995: Rembold discussed receiving a Great Idea Grant in the amount of
$300 for PULSE.
June 27 1995: Rembold advised the board of the completion of four grant proposals
and has two more to complete.
September 28, 1995: Brian Jackson informed the board that a PULSE retreat is
scheduled for November 7, 8, 9, 1995, and 29 students have been selected and are
being urged to attend.
October 26, 1995: Brian Jackson informed the board that 62 students will be attending
the PULSE retreat in November.
November 21, 1995: Rembold discussed the PULSE retreat.
March 21, 1996: Brian Jackson reported that Linda Jones and Jim Handley will be
presenting the PULSE program at the counselor's convention in Valley Forge.
October 24, 1996: Rembold informed that Rosemary Fuetuter, Linda Jones, Brian
Jackson, and himself attended the school board conference in Pittsburgh and that the
PULSE program was presented. Rembold also reported that the district received two
grants, one for $2.5 million and one for $337,000 to be used for technology.
Brian Jackson reported that the PULSE program in the process of selecting students
now for the retreat which will be at Camp Harmony on November 6, 7, and 8, 1996.
November 21 1996: Rembold discussed that the PULSE retreat was excellent.
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Brian Jackson also informed that the PULSE retreat on November 6, 7, and 8wasvery
successful.
February 27 1997: Brian Jackson discussed the PULSE Club.
July 24 1997: Rembold discussed that the PULSE program is being used as an
exemplary program in Harrisburg.
Brian Jackson informed that the PULSE Club picnic was held at Linda Jones' house
on July 19, 1997.
August 21, 1997: Rembold discussed that the PULSE program will be presented to all
of the staff on the Act 80 Day on Monday and Tuesday.
October 23, 1997: Brian Jackson, High School Principal, informed the school board
that a PULSE Retreat is scheduled for November 12, 13, and 14 at Camp Harmony.
November 25, 1997: Charles Rembold, Superintendent, informed the school board
that he just returned from Hershey, PA from a PASCD Conference and the PULSE
Program may be a national finalist. Jackson discussed that 71 students attended the
PULSE Retreat held on November 12, 13, and 14.
May 21, 1998: Rembold informed the board of several grants that he was working on.
June 25, 1998: Rembold discussed that he was working on several grants.
July 23, 1998: Rembold discussed that he was working on several grants.
November 19, 1998: Rembold informed the board that a PULSE Retreat was held at
Camp Harmony with 60 students attending. Jackson also discussed the PULSE
Retreat.
February 25, 1999: The school board unanimously passed a motion for the West
Greene School District to approve a partnership with the PULSE Program, West
Greene Lions Club, and the Senior Citizens Center at Harvey's Grange in conjunction
with the Appalachian Community Learning Project. A grant of $3,000.00 is awarded to
promote inter - generational activities between youth and senior citizens.
July 22, 1999: Rembold informed the board that he and Thelma Sz are going to
Washington, D.C. on Monday and Tuesday for a conference on 21 S Century Grants;
West Greene Administrators, Southern Columbia School District and IU 21 will be
having an in- service meeting on August 1, 2, and 3 at Seven Springs with Dr. Rembold
and Chuck presiding.
September 23, 1999: Rembold informed the board that the West Greene School
District received a School Violence Grant for $20,000.00, which will be used for
PULSE and that he submitted a grant in the amount of $50,000.00, which will be used
for the PULSE Program for Grades 4 through 12.
December 7, 1999: The school board passed a motion for the school district to
contract with Mainstream Counseling, Inc., of Huntington, PA to train a 10- person
Middle School team for the Middle School PULSE Program (at -risk students).
Program materials, training services, registration, rooms, and meals to be provided at a
cost not to exceed $9,000.00 to be paid from the Safe /Drug Free School Grant (This is
the first of two training sessions). The motion passed unanimously. It should be noted
that Rembold is present for this meeting.
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January 27, 2000: Mrs. Szarell discussed that she was in Elizabethtown with 9 staff
members from the Middle School for PULSE training and additional training will be held
in September and possibly a retreat will be held.
March 23, 2000: The school board unanimously approved a motion for the school
district to contract with Mainstream Counseling, Inc., of Huntington, PA, to train a 10-
person Middle School team for the Middle School PULSE Program (at -risk students).
Program materials, training services, registration, rooms, and meals to be provided at a
cost not to exceed $9,000.00 to be paid for from the Safe /Drug Free School Grant (this
is the second of two training sessions).
The school board also passed a unanimous motion for the school district to contract
with Mainstream Counseling, Inc. of Huntington, PA to train a 10- person Elementary
School team for the Elementary PULSE Program (at -risk students). Program,
materials, training services, registration, rooms, and meals to be provided at a cost not
to exceed $9,000.00 to be paid for from the Crime and Delinquency Grant. (This is the
first of two training sessions). Again, it should be noted that Rembold was present for
this meeting.
September 28 2000: Rembold informed the school board that the school district will
be receiving two grants, each in the amount of $150,000.00. The grants will be partly
used to coordinate the PULSE Program at all three levels.
October 26 2000: Rembold informed the school board that he has put together
several grants. Jackson reported to the school board that a PULSE Retreat will be held
November 6, 7, and 8 with 60 students attending.
The school board also passed, in unanimous motion, to create the position of Middle
School Drug Prevention and School Safety Program Coordinator in accordance with
the attached job description (to be funded by the Safe /Drug Free School Program
Grant), on a trial basis, subject to elimination after a three -year trial period in the event
the Middle School Drug Prevention and School Safety Program is determined by the
board to be concluded, ineffective, or unsuccessful, and it is eliminated by the board.
The school board also passed a unanimous motion to post and advertise for the above
mentioned position.
The school board also passed a unanimous motion for the school district to contract
with Mainstream Counseling, Inc., of Huntington, PA, to train a second Middle School
team for the Middle School PULSE Program. Program, materials, training services,
registration, rooms, and meals to be provided at a cost not to exceed $9,000.00 to be
paid for from the Safe and Drug Free Schools Program Grant.
November 2, 2000: The school board passed unanimous motion to approve Linda
Jones for the position of Middle School Drug Prevention and School Safety Program
Coordinator, which was approved at the previous school board meeting.
November 16, 2000: Rembold informed the board that the PULSE Retreat was held
on November 6, 7, and 8.
March 22, 2001: Rembold reported to the school board that he had been working on
several grants. School Board Director p an Smith, asked the Solicitor if it is a violation
of the Sunshine aw that on March 13 there was no motion passed by the board to
authorize the 21 Century Grant. Mr. Rembold stated that the grant is federal monies.
There was also lengthy discussions between citizens and members of the school
board regarding several issues concerning grants and the information in the grant
applications as well as the Greene County Vo -Tech hiring Brian Rembold (Rembold's
son) to a position. There is no official action taken regarding these discussions.
Rembold 01- 079 -C2
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April 26, 2001: A Mrs. Mancini discussed that the Middle School PULSE Retreat was
received well. There is also a notation that the Vo -Tech Representative discussed an
Administrative Management meeting that was held on March 29 , and that the Vo-
Tech is now the Fiscal Agent for a county -wide federal grant program. The board of
directors at the Vo -Tech voted to re- assign itself as the fiscal agent for the $2.6 million
21 st Century Community Learning Center Grant and accepted the resignation of Brian
Rembold as West Greene Elementary Technology Coordinator and West Greene
Community Technology Coordinator, but he will remain with the Vo -Tech four hours a
day. The Vo -Tech dissolved the hiring of a Technology Coordinator for West Greene
and approved a tentative budget in the amount of $2,182,327.00.
Also noted in the meeting minutes is that a Student Council Representative noted that
the Middle School PULSE Retreat was well received.
School Board Director Valerie Mathason, stated that the recommendation of the
superintendents to take over the grant is great, Vo -Tech does not like West Greene
asking questions and she will not apologize to anyone for asking questions. School
Board Director Smith also asked the board if the board wishes to negotiate the
superintendent's contract, if it is necessary to notify him by July 1 S one year before the
contract expires. Solicitor Rizzo said he must be notified by June 30, 2001. If not, the
board approves a motion to retain for the same term as the present contract. Rizzo
recommended several changes to the superintendent's contract.
May 17, 2001: Rembold informed the school board that during a Personnel Committee
meeting he informed the West Greene School Board that he would not be seeking
another contract and that he has started an immediate job search as superintendent in
the region.
Mancini discussed that the PULSE Group will be having a pizza party and it has been
a good first year for her and thanked Rembold, Szarell, and Jackson for all their help
and support.
August 23, 2001: A concerned citizen raises questions regarding King's Bridge Inc.
No further discussion regarding the matter is noted.
48. At Rembold's direction, WGSD applied for and received grant funds from the
Pennsylvania Department of Education Safe & Drug Free Schools program; Safe
Schools Initiative; the PA State Commission on Crime & Delinquency; Drug
Education /Law Enforcement Grant Program; and the US Department of Education,
21 S Century Community Learning Center Grant.
Rembold participated in applying for each of the grants received by the district
which participation included oversight of preparing grant applications,
determining costs, and identifying the PULSE program to be used.
Each grant applied for and received by the WGSD consisted of state or federal
funds which were distributed by the Pennsylvania Department of Education and
the Commission on Crime and Delinquency.
49. Numerous grants applied for during Rembold's tenure as superintendent (1993 -2001)
for the WGSD included utilization of the PULSE program and Mainstream Counseling
or King's Bridge.
a. Rembold was instrumental in identifying and implementing the PULSE program.
1. At this same time, Rembold was formally listed as a director and served
as an independent contractor for King's Bridge; receiving compensation
a.
b.
Rembold 01- 079 -C2
Page 15
from that entity.
50. From 1998 to 2001, Rembold, in his official capacity as superintendent of the WGSD
participated in securing a total of ten (10) separate grants from the Pennsylvania
Department of Education, the Pennsylvania Commission on Crime and Delinquency,
and theU. S.Department of Education which included proposed funding for PULSE.
a. Four (4) grants were through the Pennsylvania Department of Education office
of Safe & Drug Free Schools and Communities.
b. Two (2) grants were through the Center for Schools and Communities, Safe
Schools Initiative program overseen by the Pennsylvania Department of
Education.
1. Safe Schools Initiative grant funds come from the Commonwealth of
Pennsylvania.
c. One grant was received from the Pennsylvania Commission on Crime and
Delinquency Drug Education /Law Enforcement grant program.
d. Three (3) grants were receivd from theU. S.Department of Education,
including two (2) through its 21 Century Grant program.
e. Safe & Drug Free Schools, Drug Education /Law Enforcement Grants, are
federal funds administered by the state.
f. 21 Century Grant funds are the federal monies administered by the state.
51. Rembold's participation in securing grant funding for the district's PULSE program
included but was not limited to oversight of the grant application process and oversight
of:
a. Identifying potential funding sources at the federal, state, and local levels.
b. Identifying contractors, consultants, and non - profit and other governmental
bodies (i.e. intermediate units, police departments) to be used in connection with
the grant.
c. Identifying programs to be implemented and their costs.
52. The only contractor /consultant utilized by Rembold for PULSE training was
Mainstream Counseling.
53. Rembold participated in writing PULSE /King's Bridge Services into grant applications.
a. WGSD did not have a PULSE program prior to Rembold.
b. Rembold participated in identifying the types of goods and services for which
grant monies were requested.
c. Rembold approved the content of grant applications and /or amendments prior to
their submission.
d. Rembold directed district teachers and administrators to assist in implementing
the district's PULSE program.
e. Rembold arranged for PULSE services to be provided.
1. Rembold verified the receipt of services relating to the PULSE programs
Rembold 01- 079 -C2
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and such verification resulted in the processing of the payment of all
Mainstream Counseling invoices. The school district board of directors
subsequently would vote to pay these invoices.
f. Rembold was the source of the raw data and budget figures needed to complete
the grant applications.
54. Rembold advised WGSD administrators, that a PULSE program would be implemented
in the district.
55. Rembold advised WGSD administrators that he created the PULSE program and that
it would suit district needs.
a. Other components were added to the program to provide a comprehensive
student model.
56. The WGSD Board did not specifically vote on the initiation or implementation of the
PULSE program in the school district.
57. The Pennsylvania Commission on Crime and Delinquency (PCCD) made federal grant
money available through its Pennsylvania Drug Education /Law Enforcement Grant
Program.
a. School districts throughout the state were notified of available grant money
through PCCD as part of the program.
b. Interested districts were required to complete and submit a grant application to
the PCCD outlining the amount requested and its intended use.
58. On August 16, 1999, the PCCD received a Pennsylvania Drug Education/Law Enforcement
Grant Program application in the amount of $16,121.00 from the WGSD.
a. The application was submitted by Rembold.
b. The project title was listed as PULSE (People Utilizing Leadership Skills
Effectively).
c. Rembold was listed as the district's contact person.
d. The grant period is identified as being from September 15, 1999, to June 30,
2000.
e. Rembold signed the grant's law enforcement /school cooperative agreement in
his official capacity as superintendent on August 16, 1999.
f. Rembold signed a related consortium participation agreement in his official
capacity as superintendent on August 16, 1999.
59. The program objectives included the implementation of a PULSE programfor60at -risk
students in grades 7 -12, the training of 10 WGSD /community members as PULSE
facilitators, a three -day student /adult retreat, and maintenance of a PULSE club.
a. The objectives were approved by Rembold.
60. On January 27, 2000, the PCCD forwarded the grant to the WGSD for the district's
approval.
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Page 17
a. Rembold, on behalf of the school district, signed the grant acceptance
statement in the amount of $16,121.00 for the "PULSE Program" project.
b. Rembold's signature represents that he on behalf of the district agrees to
accept the grant "on the condition that you comply, in administering your
program, with all representations contained in your application as amended and
with the enclosed standard sub -grant conditions of the Commission."
61. The PCCD issued two (2) payments to the West Greene School District honoring its
$16,121.00 grant obligation to the district.
a. $8,091.00 was issued to the district on January 20, 2000.
b. $8,030.00 was issued to the district on June 7, 2000.
62. The West Greene School District did not seek any competitive bids for the PULSE
program portion of this grant.
a. Rembold participated in the decision to utilize the King's Bridge's PULSE
program as part of this grant.
b. During this time period when Rembold took actions regarding this grant,
Rembold was an independent contractor paid by King's Bridge Incorporated,
and was formally listed as a director of King's Bridge Incorporated.
63. The WGSD Board of Directors did not take any official action approving the
submission of the PCCD $16,121.00 grant application.
64. The Pennsylvania Department of Education makes federal grant mone y available to
school districts through its Office of Safe Schools based on need and district
enrollments.
a. School districts submit grant applications to the Department of Education
detailing intended program uses for the funding.
65. On December 5, 1997, the Pennsylvania Department of Education sent notification to
Rembold at the WGSD of the availability of funds from the Safe & Drug Free Schools
Program.
a. On April 17, 1998, the WGSD received notification that it would be allocated
$6,101.00 provided it submitted a completed application to the Department of
Education by July 1, 1998.
66. The West Greene School District received the grant of $6,101.00 from the
Pennsylvania Department of Education Safe and Drug Free Schools program for the
1998 -1999 allocation period.
a. WGSD Director of Instructional Services, Frank Blout, was identified as the
district contact person with Jeane Pulkownik being the fiscal contact.
67. Fiscal records of the Department of Education confirm this grant was paid in three (3)
installments to the district between March 16, 1999, and May 17, 1999 as follows:
Allocation Period: 1999 Amount
03/16/1999 $ 1,626.92
04/16/1999 $ 406.73
05/17/1999 $ 4,067.35
Total $ 6,101.00
Rembold 01- 079 -C2
Page 18
68. Rembold signed the grant completion report for this project on June 23, 1999.
69. Rembold participated in or had oversight responsibilities for the following actions with
respect to the $6,101.00 Safe & Drug Free Schools 1998 -1999 grant program:
a. Completion and submission of a detailed grant contract that included PULSE, a
program administered by King's Bridge;
b. Selection of PULSE training for district employees;
c. Approval of grant expenditures;
d. Identification of district staff to be used;
e. Signed letters of assurance with local law enforcement agencies; and
f. Signed final grant completion report.
70. On November 18, 1998, the Department of Education's Bureau of Community and
Student Services sent notification to Rembold as superintendent advising of funding
available for the federal Safe and Drug Free Schools and Communities Act Fund for
1999/2000.
a. On May 7, 1999, Rembold was sent correspondence from the Department of
Education informing him that WGSD's allocation from the 1999/2000 federal
Safe and Drug Free Schools and Communities program was $5,032.00.
71. On June 29, 1999, Rembold, in his official capacity of superintendent, signed the grant
application for the 1999 -2000 PA Department of Education grant.
a. Information in the application was physically prepared by the West Greene
School District federal program staff.
b. This application was reviewed and approved by Department of Education on
January 20, 2000.
c. The funding period is identified as July 1, 1999, through September 30, 2000.
d. This application included the following program summary:
Activity Cost
Leadership training for at -risk students- $3,632.00
PULSE training.
Post training survey on ATOD use and $1,400.00
structured interviews.
Total: $5,032.00
e. Included with application was a reference to WGSD's intent to utilize the grant
funds to support the district's PULSE program.
f. Rembold received notification of approval of this grant from the Department of
Education on February 17, 2000.
g. Members of the West Greene School District Board of Directors signed the
grant application as members of the Safe and Drug Free Schools and
Community Advisory Council.
72. Rembold was the contact person and recipient of correspondence dated May 11, 2000,
Rembold 01- 079 -C2
Page 19
and July 24, 2000, related to a rider amendment needed to extend the ending date of
this grant.
73. Fiscal records of the Department of Education confirm the grant was aid in three (3)
separate installments to the district between March 16, 2000, and May 16, 2000 as
follows:
Allocation Period: 1999 -2000 Total
03/16/2000 $ 1,341.88
04/17/2000 $ 335.47
05/16/2000 $ 3,354.65
Total $ 5,032.00
74. Rembold, as superintendent, participated in or had oversight responsibilities for the
following actions with respect to the $5,032.00 Safe & Drug Free Schools 1999 -2000
grant program:
a. Identification of the funding source;
b. Served as the district's contact person;
c. Completion of the grant application which identified use of the PULSE Program.
d. Completion of progress reports adjusting budget figures;
e. Approval of budget expenditures which include PULSE program fees;
f. Identification of staff to be used to complete the grant.
75. On or about December 22, 1999, Rembold received notification of the Department of
Education regarding funding from the federal Safe & Drug Free Schools and
Communities Act funds for 2000/2001.
76. Rembold, as superintendent, signed the grant application seeking funds for the 2000-
2001 grant period.
a. Rembold requested funding totaling $4,825.00.
b. The funding period was identified as July 1, 2000, through September 30, 2001.
c. This application included the following program summary.
Activity Cost
Leadership training for at -risk students $1,225.00
PULSE training.
Leadership training for at -risk students $3,600.00
PULSE training.
Total: $4,825.00
d. Included with the application is a program narrative detailing a PULSE survey
and PULSE program, no mention of King's Bridge is included.
e. School Board President Debra Crouse also signed the grant application
acknowledging that she had been consulted and actively involved in the
application.
Rembold 01- 079 -C2
Page 20
77. Rembold received notification of the grant approval on or about May 10, 2000.
78. Fiscal records of the Department of Education confirm this grant was paid in four (4)
separate installments to the district between July 19, 2001, and February 15, 2002 as
follows:
Allocation Period:
2001 -2002 Amount
07/19/2001 $1,286.68
08/16/2001* $ 321.67
09/17/2001* $ 321.67
02/15/2002* $2 894.98
Total: $4,825.00
*These payments were made after Rembold's resignation as superintendent.
79. Rembold participated in or had oversight responsibilities for the following actions with
respect to the $4,825.00 Safe & Drug Free Schools and Communities 2000 -01 grant
program.
a. Identification of the funding source, completed the grant application and signed
grant application;
b. Served as the district contact person;
c. Identification of staff to be used to complete this grant.
80. The Safe and Drug Free School and Communities 2000 -01 grant application was
physically completed by the West Greene School District federal programs staff.
a. School Board President Debra Crouse signed the application indicating that she
had been actively consulted and involved in the development of the application.
81. Rembold sought grants while employed as WGSD Superintendent, from Department of
Education's Safe Schools Initiative grant program.
a. Department of Education grant money provided through the department's Safe
Schools Initiative office that was administered by the Central Susquehanna
Intermediate Unit under the auspices of its Center for Safe Schools.
b. Funding for the Safe Schools Initiative grants is funding from the state that is
administered through the Center for Safe Schools.
82. Rembold submitted a district grant application to the Pennsylvania Department of
Education, Office of Safe Schools, Bureau of Community and Student Services, with
his name as contact person on May 11, 1999, for the 1999/2000 safe schools
initiative.
a. This grant application was in the amount of $20,000.00 with the district
contributing matching funds of $31,011.00 for total project costs of $51,011.00.
b. Rembold completed this grant application for submission to the PA Department
of Education.
c. Rembold is listed as the contact person as superintendent with a contact e-mail
address of rembold @alltel.net.
Rembold 01- 079 -C2
Page 21
83. Rembold stated in the grant application that the purpose for obtaining the grant was to
enable the WGSD to implement a PULSE (People Utilizing Leadership Skills
Effectively) Program as a prevention/ intervention school -based community inclusive
program designed to meet the needs of adolescents who are at high risk toward
unhealthy behaviors.
a. The application noted that the program period was to be July 1, 1999 to June
30, 2000 to target sixty (60) at -risk WGSD students from grades 7 -12 to be
recruited through a school /interagency process.
b. A PULSE "core training staff" will be contracted to provide: (1) school/
community planning team training; (2) facilitator training in PULSE techniques;
(3) scheduling /management of a three -day student -adult experiential retreat; (4)
PULSE Club implementation; and (5) program evaluation.
c. The application noted that the overall goal of the program was to achieve safer
learning environments for children and staff.
d. The application results and objects were directed at utilizing the PULSE
programming developed by Kings Bridge.
Objective 1: Implement a PULSE Program for sixty (60) "at- risk" students in
grades 7 -12 that will encourage appropriate decision - making through prevention
and intervention program.
Objective 2: Identify and refer sixty (60) WGSD students for PULSE Program
participation.
Objective 3: Train ten (10) WGSD /Community members as PULSE facilitators.
Objective 4: Provide a three -day student /adult retreat focusing on relationship,
building activities that promote positive social bonds between retreat facilitators
(teachers, police, business persons) and "at- risk" students.
Objective 5: Maintain a PULSE Club to: (1) provide alternative activities
(social /community service) for at -risk youth; (2) promote positive relationship
building; and, (3) develop an emotional support system.
Objective 6: Execute formative and summative evaluation on PULSE Program
components through quantitative and qualitative data collection procedures.
e. Design and operation of the program was identified as the following:
The West Greene School District will implement a PULSE (People Using
Leadership Skills Effectively) Program for the program period of July 1, 1999,
through June 30, 2000. The program will be a prevention/ intervention, school -
based, community inclusive program designed to address the needs of
adolescents who are at high -risk toward unhealthy behaviors.
84. The grant application submitted by Rembold specified that the WGSD would contract
with King's Bridge Inc., to implement a PULSE Program.
a. The PULSE core training staff was identified as follows:
Attachment E. PULSE Program Management/Training Staff
Name Position
Charles Rembold Superintendent West Greene School District
Edgar Thacker Assistant Superintendent on Nat'l. Alternative Schools
Rembold 01- 079 -C2
Page 22
Steve Wilcox
Art Waleski
Lonnie A. Woomer
Brian Jackson
Linda Jones
Lucille Aloisi
d.
e.
f.
Programs
Assistant Superintendent, Camp Hill School District
Assistant, Principal, Huntingdon Area School District
Executive Director /Owner, Mainstream Counseling
High School Principal, West Greene School District
Teacher, West Greene School District
Independent Consultant /Owner, Aloisi Consulting Services
85. Rembold p rovided background on the PULSE program with the grant application which
described the PULSE Program as being developed over a twenty -year period with its
roots firmly planted in substance abuse prevention, intervention, and community action
planning.
a. The research and development team composed of three (3) educators and a
substance abuse professional designed, field tested and evaluated activities
responsive to the needs from communities requesting services to address
substance abuse and related issues in the early 1980s.
b. In Virginia, these initial training services led to the formation of school -
community teams.
c. Rembold submitted with the application a PULSE organizational chart detailing
involved business entities and individuals relative to the grant and its
administration, including King's Bridge Inc. which was identified as program
marketing, development management, implementation and evaluation.
86. The three educators Rembold referenced in his background description of the PULSE
program included Wilcox, Thacker, and himself.
87. On October 25, 1999, Rembold signed a letter of agreement with the Central
Susquehanna Intermediate Unit securing the $20,000.00 grant.
a. This grant was paid to the West Greene School in two $10,000.00 installments.
1. An initial $10,000.00 payment was made to the district on or about
November 5, 1999.
2. A second $10,000.00 payment was made to the district on or about
August 21, 2000.
88. Rembold participated in or had oversight responsibility for the following actions with
respect to the district's $20,000.00 Safe Schools Initiative Grant program for 1999-
2000.
a. Identification of the funding source and prepared the application;
b. Identification of the consultants and vendors to be used, including King's Bridge;
c. Identification of the services to be provided, including King's Bridge's PULSE
program;
Fixing and approval of the grant budget;
Identification of the district staff to be used;
Served as the district contact person;
Rembold 01- 079 -C2
Page 23
g. Completion of and submission of the grant application;
h. Signed grant agreement letters with the Central Susquehanna Intermediate
Unit; and
Approved grant expenditures, including fees for King's Bridge and /or the
PJLSE program.
j. Monitored programs, including reviewing the PULSE program.
89. Rembold submitted a WGSD district grant application to the Pennsylvania Department
of Education, Office of Safe Schools, Bureau of Community and Student Services, on
September 23, 1999, for the 1999 -2000 Safe Schools Initiative grant program.
a. The application identified Rembold as the program director.
b. Rembold is listed under program director category with the title superintendent.
c. This grant request was in the amount of $50,000.00 with the district contributing
matching funds of $36,828.00 for total project costs of $86,828.00.
90. The grant application included a listing of contractors /consultants and specifically noted
the WGSD will contract with King's Bridge Inc., to implement a PULSE program.
a. Rembold, along with the PULSE training staff, are identified as having various
responsibilities for the program.
b. Rembold is specifically identified as being responsible for implementing a
PULSE program for 120 "at- risk" students in grades 4 -8 to encourage
appropriate decision making through prevention and intervention activities.
91. On December 7, 1999, Rembold was notified by the Department of Education that of
the $50,000.00 requested, a $26,400.00 grant was awarded.
a. Rembold was instructed to submit revised budget figures based on the reduced
award.
92. On December 15, 1999, Rembold submitted a revised budget to the Department of
Education to accommodate a reduction in grant funding to $26,400.00.
93. Rembold signed a letter of agreement with the Central Susquehanna Intermediate Unit
accepting the $26,400.00 grant awarded on February 11, 2000.
94. Fiscal records of the Center for Safe Schools confirm that this grant was paid in two (2)
separate installments as follows:
a. Date Amount
March 2000 $ 5,280.00
June 2000 $21,120.00
Total $ 26,400.00
95. Rembold participated in or had oversight responsibilities for the following actions with
respect to the district's $26,400.00 Safe Schools Initiative grant program for 1999-
2000.
a. Identification of the funding source;
Rembold 01- 079 -C2
Page 24
b. Identification of consultants and vendors to be used, including King's Bridge;
c. Identification of services to be provided, specifically the PULSE program;
d. Inclusion of King's Bridge for PULSE training into the grant;
e. Fixing and approval of the grant budget which included fees to be paid to King's
Bridge and /or PULSE;
f. Identified district staff to be used;
g. Served as the district contact person;
h. Completion and submission of the grant application and budget revisions;
Signed grant agreement letters with the Central Susquehanna Intermediate
Unit; and
j. Approval of grant expenditures for King's Bridge.
96. Rembold oversaw the administration of this grant in his official capacity as WGSD
superintendent.
a. Rembold was simultaneously compensated by King's Bridge Inc. as a
independent contractor during the time period when he used the authority of his
position to ensure King's Bridge's /PULSE program was used.
97. In addition to grant funding requested from the state, Rembold, as superintendent of
WGSD, applied for grant funding from theU. S.Department of Education.
a. WGSD secured three (3) grants from the US Department of Education,
including two (2) 21 Century Community Learning Center (CCLC) grants.
98. Rembold oversaw the submission of an application to theU. S.Department of Education
for a CCLC grant for the WGSD Middle School.
a. The application prepared by Rembold sought total federal funding of
$268,297.00.
b. The specified grant period was July 1, 1999, through June 30, 2002.
c. Rembold signed the application as the authorized representative of the WGSD
on February 24, 1999.
d. The application's stated purpose of the 21 Century Grant was to establish a
community learning center in the West Greene Middle School.
1. The community learning center is to positively influence development of
youth using the PULSE (People Utilizing Leadership Skills Effectively)
Youth Leadership model.
e. The application was submitted by WGSD on behalf of a partnership between
West Greene Middle School and district and the Vo -Tech High School,
Waynesburg College, Greene County Commissioners, Washington Job
Training Agency, Inc., Greene County Industrial Development, Inc., Greene
County Library, and Greene County Memorial Hospital.
Rembold 01- 079 -C2
Page 25
99. The grant application provides that PULSE would be utilized for youth development
activities.
a. Rembold is identified in the application as a creator of PULSE.
100. Rembold was formally listed as a director of King's Bridge Inc. at the time of this grant.
101. Rembold was receiving compensation from King's Bridge Inc. at the time of this grant.
a. Rembold's first payment as an independent contractor for King's Bridge
Incorporated was received on January 25, 2000.
b. The grant application had been submitted prior to this payment.
102. The Greene County Educational Consortium of which Rembold was a member,
oversaw the submission of a second application to the US Department of Education for
a county -wide CCLC grant.
a. The application sought total federal funding for the project of $2,650,917.00 for
three (3) years.
b. The specified grant period was July 1, 2000, through June 30, 2001.
c. Rembold signed the application as the authorized representative of the WGSD
on March 20, 2000.
d. The application's stated purpose of the 21 Century Grant was to establish a
countywide 21 Century Community Learning Center.
1. The community learning centers would utilize social development and
juvenile crime diversion activities using the People Utilizing Leadership
Skills Effectively (PULSE) model.
2. The CLC's will be coordinated by full or part -time professionals who will
be trained as trainers in the PULSE model.
e. The application was submitted by WGSD on behalf of a partnership between
West Greene School District, Vo -Tech, Central Greene School District,
Southeastern Greene School District, Carmichaels Area School District, and
Jefferson - Morgan School District.
f. Program Costs included specific PULSE expenses as follows:
1. Graysville and Aleppo Elementary Schools PULSE Training -
$13,492.00.
2. Mapletown Jr. /Sr., Jefferson - Morgan Jr. /Sr., Carmichaels Jr. /Sr. High
Schools and Miller Middle School PULSE training $28,440.00.
3. Vo -Tech School PULSE training - $7,082.00.
103. The WGSD was the original fiscal agent for this grant.
a. The county Vo -Tech was appointed as the fiscal agent in May 2001 after
concerns were raised by members of the WGSD board of directors and the
superintendents from the other county school districts.
104. Rembold was formally listed as a director of King's Bridge Inc. at the time of this grant.
Rembold 01- 079 -C2
Page 26
105. Rembold was receiving compensation from King's Bridge Inc. at the time of this grant.
106. Rembold oversaw the submission of another application to the US Department of
Education for the hiring of a Middle School Drug Prevention and School Safety
Program Coordinator.
a. The application sought total federal funding for the project of $198,598.00 for
three (3) years.
b. The specified grant period was October 1, 2000, through February 28, 2003.
c. Rembold signed the application as the authorized representative of the WGSD
on May 10, 2000.
d. The application's stated purpose of the grant was to hire a Middle School Drug
Prevention and School Safety Program Coordinator.
1. The Middle School Drug Prevention and School Safety Program
Coordinator was to support the district's PULSE activities.
107. This grant application was submitted to support PULSE activities.
108. Rembold was formally listed as a director of King's Bridge Inc. at the time of this grant.
109. Rembold was receiving compensation from King's Bridge Inc. at the time of this grant.
110. Mainstream Counseling was utilized by King's Bridge to contract with the WGSD for
PULSE related services in relation to grants received by the WGSD, including Safe
Schools Initiative, Safe & Drug Free Schools, andU. S.Department of Education.
111. Mainstream Counseling invoiced and was paid by the WGSD for PULSE related
services associated with the Safe Schools Initiative, Safe and Drug -Free Schools, and
US Department of Education Grants as follows:
Date Invoice # Bill To Description Amount
12 -07 -99 7501 Rembold High School Pulse $ 8,550.00
(WGSD) Admin Fee 450.00
Total: $ 9,000.00
Date Invoice # Bill To Description Amount
03 -13 -00 7502 Rembold Middle School Team $ 8,550.00
(WGSD) May 9- 10 -11, 2000
Admin Fee 450.00
Total: $ 9,000.00
Date Invoice # Bill To Description Amount
03 -13 -00 7503 Rembold Elem. School Team $ 8,550.00
(WGSD) May 9- 10 -11, 2000
Admin Fee 450.00
Total: $ 9,000.00
Date Invoice # Bill To Description Amount
04 -25 -00 7504 Rembold Middle School $ 2,850.00
(WGSD) Curriculum Dev.
Admin Fee 150.00
Total: $ 3,000.00
Date Invoice # Bill To Description Amount
Rembold 01- 079 -C2
Page 27
04 -25 -00 7505 Rembold
(WGSD)
Date Invoice # Bill To
05 -22 -00 7506 Rembold
(WGSD)
Date Invoice # Bill To
11 -17 -00 7507 Rembold
(WGSD)
Date Invoice #
12 -0700 7508
Mainstream
Date
12/17/1999
04/05/2000
04/24/2000
05/08/2000
06/01/2000
12/20/2000
01/10/2001
Counseling
Check No.
20379
20897
20930
21050
21218
22426
22495
Bill To
Rembold
(WGSD)
Curriculum (Prep.)
Development /Manual
Admin Fee
Total:
Description
Curriculum Devel.
Supplies
Admin Fee
Total:
Description
Support personnel for
retreat on Nov. 6 -7 -8,
2000
Admin Fee
Total:
Description
Middle School PULSE at
Elizabethtown
Admin Fee
Total:
Grand Total:
Amount
$ 9,000.00
$ 9,000.00
$ 9,000.00
$ 4,500.00
$ 3,533.13
$ 9,000.00
$ 2,000.00
$46,033.13 [sic]
$ 1,425.00
750.00
$ 1,500.00 [sic]
Amount
$ 3,325.00
33.13
175.00
$ 3,533.13
Amount
$ 1,900.00
100.00
$ 2,000.00
Amount
$ 8,550.00
450.00
$ 9,000.00
$46,033.13 [sic]
112. Financial records of the West Greene School District confirm the following payments
were made to Mainstream Counseling for PULSE program related services:
a. Payments made directly to Mainstream Counseling were charged off to Safe
Schools Initiative, Safe and Drug -Free Schools, and US Department of
Education Grants.
b. Payments made to Mainstream Counseling were the result of purchase
invoices submitted to WGSD.
113. Rembold, as superintendent, authorized submission of all of the payments from
Mainstream Counseling to the WGSD Board for approval.
a. Rembold verbally authorized for submission to the board Invoice Nos. 7501,
7502, 7503, 7506, 7507 and 7508.
1. WGSD business manager would not have generated checks to pay
these invoices absent Rembold's approval.
b. Rembold authorized for submission to the board Invoice Nos. 7504 and 7505
Rembold 01- 079 -C2
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by initialing those invoices.
114. Mainstream Counseling invoiced and was paid by the GCVT for PULSE related
services associated with the US Department of Education Grants as follows:
a. Invoice No. 7509 from Mainstream dated 5/24/01 in the amount of $35,000.00
for the following:
Date
06/20 -2001
03/20/2002
09/18/2002
June 11, 12, 13 and 14, 2001, training, materials, and food for 5 Greene
County PULSE teams at Waynesburg College:
10- person team
10- person team
10- person team
10- person team
10- person team
b. Invoice No. 8502 from Mainstream dated 2/01/02 in the amount of $28,000.00
for the following:
March 6, 7, and 8, 2002, PULSE facilitator training by 6 trainers. Includes fees;
registration materials; training manuals; documents, and supplies. Also to
include pre and post site visits and planning time.
6- person team —
6-person team —
6-person team —
6-person team —
7- person team
7- person team
7- person team
7- person team
7- person team
— Southeast Greene SD
— Jefferson - Morgan SD
— Central Greene SD
— Carmichaels SD
— West Greene SD
Carmichaels SD
Central Greene SD
Jefferson - Morgan SD
Southeast Greene SD
— Carmichaels High School
— Waynesburg High School
— Jefferson- Morgan High School
— Mapletown High School
— West Greene High School
Check No.
3228
4005
4578
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
c. Invoice No. 7520 from Mainstream dated 9/10/02 in the amount of $35,000.00
for the following:
September 25, 26, and 27, 2002, PULSE facilitator training by 7 trainers.
Includes fees; registration materials; training manuals; documents and supplies.
Also to include pre and post site visits and planning time.
115. Financial records of the GCVT confirm the following payments
Mainstream Counseling for PULSE program related services:
Amount
$35,000.00
$28,000.00
$35 000.00
$98,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
- $ 7,000.00
were made to
a. Payments made directly to Mainstream Counseling were charged off to Safe
Schools Initiative, Safe and Drug -Free Schools, and US Department of
Education Grants.
b. Payments made to Mainstream Counseling were the result of purchase
invoices submitted to GCVT.
Rembold 01- 079 -C2
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116. The WGSD and the GCVT paid Mainstream a total of $144,033.13 for services related
to the PULSE program.
117. Mainstream invoiced the WGSD and GCVT as per the billing agreement between
Mainstream Counseling and King's Bridge.
a. As per this agreement, Mainstream Counseling billed WGSD and GCVT for
services rendered by KBI for the PULSE related training.
b. Mainstream Counseling kept 5% of the payment and transmitted the remaining
funds to KBI.
c. Rembold participated in negotiating the agreement as a representative of King's
Bridge with the WGSD.
d. Rembold had no involvement with Mainstream Counseling, Inc.'s services to
GCVT. These particular services were negotiated by Linda McCracken, who
was the Director of the 21 S Century Program for the Greene County
Educational Consortium, and Lonnie Woomer, Executive Director of
Mainstream Counseling, Inc. All expenditures for GCVT were approved by the
Joint Operating Committee of the GCVT school.
118. Rembold was formally listed as a director of King's Bridge Inc., during the entire time
(1993 -2001) he was administering grants and authorizing payments to Mainstream
Counseling.
a. Rembold was also compensated as an independent contractor to conduct
King's Bridge training during this period and for developing the Middle School
PULSE Model, the PULSE +3 Model for adjudicated youth, and the
development of a rural economic development strategy for rural communities.
119. Mainstream issued payments totaling $136,900.00 to King's Bridge for PULSE related
services provided to WGSD and GCVT associated with the Safe Schools Initiative,
Safe and Drug -Free Schools, and US Department of Education Grants as follows:
a. WGSD:
Date P.O. # Description Amount
12 -07 -99 58014 Level 2 PULSE training on Jan. 11- $8,550.00
12 -13, 2000.
12 -07 -99 58014 Level 2 PULSE training on Jan. $8,550.00
11- 12 -13, 2000.
03 -31 -00 58023 Upper Elem. School PULSE $8,550.00
May 9- 10 -11, 2000
04 -24 -00 58034 Curriculum Development $2,850.00
Manual Preparation $1 425.00
Total: $4,275.00
05 -22 -00 58040 Curriculum Dev. For Middle $3,425.00
School
11 -17 -00 58008 Three trainers for retreat on Nov. $1,900.00
6 -7 -8, 2000
12 -11 -00 58037 Training for Middle School PULSE $8,550.00
on Feb. 7 -8 -9, 2001
Rembold 01- 079 -C2
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b.
1.
GCVT:
Sub - total: $43,800.00
Payment made to King's Bridge on 04/24/00 was derived from
payment of two invoices submitted by Mainstream to the WGSC.
King's Bridge Invoice No. 58039
King's Bridge Invoice No. 58031
King's Bridge Invoice No. 58046
Sub - total:
$33,250.00
$26,600.00
$33 250.00
$93,100.00
120. Mainstream issued payment to King's Bridge as per the billing agreement between
Mainstream Counseling and King's Bridge.
a. Rembold was present when this agreement was negotiated.
b. Rembold was formally listed as a director of King's Bridge Inc., and was
employed by King's Bridge as an independent contractor during the entire time
(1998-2001) he was administering grants and authorizing payments to King's
Bridge and Mainstream Counseling.
c. Mainstream Counseling charged a flat administrative fee of 5% for the
submission of bills to the West Greene School District relating to the provision
of PULSE programs to that district.
121. Rembold oversaw the inclusion of the services provided by King's Bridge and
Mainstream Counseling into grant applications he submitted.
a. During the time period when he was participating in the award of contracts to
Mainstream Counseling, Rembold was being compensated by King's Bridge as
an independent contractor and was also formally listed as a King's Bridge
director.
122. Rembold's actions securing Safe Schools Initiative, Safe and Drug -Free Schools, and
US Department of Education grants resulted in a private pecuniary gain to King's
Bridge of $136,900.00.
123. Payments made to Mainstream Counseling from WGSD were made from the district's
general fund account.
a. This account was funded in part by the aforementioned grants.
b. Rembold, in his position as superintendent of the WGSD, had participated in
obtaining these grants as heretofore delineated.
124. Payments made to Mainstream Counseling from GCVT were made from the school's
general fund account.
a. This account was funded in part by the aforementioned grants.
125. During the period when Rembold was taking actions as WGSD Superintendent relating
to the award of contracts to King's Bridge and /or Mainstream Counseling, and the
obtaining grants relative to services rendered by these entities he received payments
totaling at least $27,795.00 from January 2000 through July 10, 2001, from King's
Bridge.
Rembold 01- 079 -C2
Page 31
a. These payments were related to program development and trainer/ consultant
services development of the PULSE +3 model, the middle school model and the
rural economic development model provided by Rembold in relation to PULSE
programs and King's Bridge activities with school districts.
b. Payments to Rembold from King's Bridge's First Union account.
Date Check No. Amount
01/25/00 1613 $ 3,500.00
05/08/00 1626 $ 412.00
05/10/00 1628 $ 65.00
05/10/00 1634 $ 4,000.00
06/15/00 1639 $ 2 000.00
Total $ 9,977.00
c. Payments to Rembold from King's Bridge's American Community Federal
Credit Union account.
Date Check No. Amount
07/25/00 1005 $ 2,000.00
02/13/01 1019 $ 4,000.00
04/12/01 1027 $ 2,000.00
05/02/01 1030 $ 318.00
05/18/01 1031 $ 4,000.00
07/10/01 1040 $ 5 500.00
Total $ 17,818.00
d. Fourteen thousand dollars ($14,000) in payments to Rembold from King's
Bridge Incorporated represented expenses for writing a middle school PULSE
manual, developing the PULSE +3 Model and creating a rural economic
development model.
126. Rembold's first payment from King's Bridge Inc., on January 25, 2000, occurred
approximately two weeks after the first training for WGSD was completed on January
11 -13, 2000.
a. Rembold had never received any funds from King's Bridge Inc. prior to the time
that King's Bridge Inc. did business with the WGSD.
127. M. Steven Wilcox was paid a total of $27,900 by King's Bridge Inc. during this same
timeframe.
a. King's Bridge Inc. was providing PULSE training in the Southern Columbia
Area School District where Wilcox served as superintendent.
b. The PULSE training provided at SCSD by King's Bridge Inc. was paid for with
grant funding.
c. Wilcox was one of the PULSE originators and a King's Bridge Inc. director.
d. Wilcox had never received any funds from King's Bridge Inc. prior the time that
King's Bridge Inc. did business with Wilcox's school district.
128. Rembold asserts that he was never compensated by King's Bridge Inc. for training
performed for the WGSD.
129. All of the funds received by King's Bridge Inc. from WGSD, SCSD and HASD were
deposited into the same bank account.
Rembold 01- 079 -C2
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130. All payments to Rembold, Wilcox, Waleski and the other PULSE Core Training staff
came from the sole King's Bridge Inc. bank account.
131. Because all of the funds received by King's Bridge Inc. were commingled specific
funds emanating from a particular school district can not be traced as going to any
specific member of the PULSE Core Training Team.
132. Payments issued to Rembold from King's Bridge did not begin until after King's Bridge
received payments from the West Greene, Southern Columbia, and Huntingdon Area
School Districts (HASD).
133. King's Bridge Inc., was a dormant company from January 1996 until January 2000
maintaining an account balance of approximately $3,117.59.
a. The King's Bridge accounts showed increased deposits and withdrawals
following the acquisition of contracts with the WGSD.
b. Steven Wilcox, also a director of King's Bridge and then superintendent of
Southern Columbia School District (SCSD), was actively participating in the
acquisition of grant funds to implement the PULSE Program and hire King's
Bridge Inc. at the SCSD.
c. Funds received by King's Bridge from WGSD, SCSD, and HASD comprised
the majority of the deposits into King's Bridge accounts.
134. King's Bridge Inc. did not show as a vendor at the WGSD because of its agreement
with Mainstream Counseling.
a. Mainstream Counseling submitted all bills relating to the provision of PULSE
services to the West Greene School District on behalf of King's Bridge
Incorporated.
b. Mainstream Counseling was identified as the service provider on applications/
budgets when obtaining grants even though the actual provider would be King's
Bridge.
c. Mainstream Counseling provided no services to WGSD in relation to the
Pennsylvania Department of Education, Pennsylvania Commission on Crime
and Delinquency, andU. S.Department of Education Grants.
d. Mainstream Counseling's only service was to submit invoices to the WGSD.
e. Mainstream deducted 5% of the total as administrative costs and forwarded the
balance to King's Bridge.
The following findings relate to allegations that Rembold secured grant funding for
technology coordinator positions that he developed for his son and for which his son
was ultimately hired
135. The Greene County Vo -Tech (GCVT) is funded by and provides services for the five
school districts in Greene County.
a. Rembold is not employed by the Vo -Tech.
b. The Vo -Tech is a separate entity from the WGSD.
c. The WGSD is one of the school districts covered by the GCVT.
Rembold 01- 079 -C2
Page 33
136. The vo -tech is governed by a five - member Joint Operating Committee (JOC)
comprised of one school board member from each of the five school districts.
a. The JOC has meetings once per month and makes decisions regarding fiscal
and employee matters.
b. A director supervises the day -to -day activities of the vo -tech.
137. The vo -tech also has a superintendent of record who is a superintendent from one of
the five county school districts.
a. The term for the superintendent of record is two - years.
138. The superintendent of record serves as the superintendent of the vo -tech, chairs the
JOC meetings, and acts as the director in the director's absence.
139. Bryan Rembold, Rembold's son, has been employed by the Greene County Vo -tech
School as a technology coordinator since July 1, 2000.
a. Bryan Rembold served as an intern for the vo -tech during the summer months
in 1999 and 2000 prior to being hired as a regular employee of the vo -tech.
140. From July 2000 through February 2001, Bryan Rembold worked eight hours per day
strictly for the vo -tech that was funded solely by the vo -tech.
a. Bryan Rembold's salary was $45,000 per year plus benefits.
141. Beginning on March 1, 2001, Bryan Rembold's twelve hour work day was split
between the vo -tech (four hours) and the WGSD (four hours) and the West Greene
Community (four hours).
a. Brian Rembold's salary was funded fifty- percent by the vo -tech and fifty- percent
from the (2001) Greene County 21 S Century Community Learning Center
Grant.
b. Bryan Rembold's salary was to be $60,000.00 per year (including benefits).
142. Rembold, as the WGSD superintendent, participated in securing the West Greene
Middle School 21 Century Community Learning Center Grant. (See Findings 130
through 135)
143. At Rembold's request, the WGSD board of directors approved funding from the 2001
Greene Education Noll Consortium 21 st Century Community Center Learning Grant for
the services of a technology coordinator to include four hours of work daily as technical
coordinator for the West Greene Elementary Schools and four hours as technology
coordinator for the West Greene School District Community.
144. By letter dated January 26, 2001, Rembold informed the Joint Operating Committee of
the Vo -Tech that the WGSD board approved funding for the technology coordinator,
and he requested that his son be hired for this position.
145. The JOC reassigned Bryan Rembold to this position effective March 1, 2001.
146. At the time, the JOC reassigned Bryan Rembold it was comprised of the following
members:
Rembold 01- 079 -C2
Page 34
Member
John Walters
Ron Jesso Central Greene
Remo Bertugli Jefferson - Morgan
Mike Conte Carmichaels
School Board Note
West Greene Retired Weste Teacher
Current West Greene Teacher
Current West Greene Teacher
Jefferson - Morgan Business
Administrator
George Billitz Southeastern Greene None
147. At the time of Rembold recommended the JOC utilize his son for the position, he was
the immediate supervisor of two of the members of the JOC in their capacity as
teachers at the WGSD
148. Bryan Rembold resigned as the technology coordinator for the West Greene Middle
School on April 18, 2001.
149. Bryan Rembold was compensated $3,786.92 by the vo -tech from the Greene County
Educational Consortium of which Rembold is a member and the financing of which was
obtained from a grant secured by Rembold.
150. From April 18, 2001 until June 10, 2001, Bryan Rembold remained an employee of the
vo -tech as a technology coordinator for four hours per day funded solely by the vo-
tech.
151. Effective June 11, 2001, the JOC reassigned Bryan Rembold to work eight hours per
day for the vo -tech and for four (4) schoof districts in the county (except West Greene
that was funded fifty - percent by the vo -tech and fifty - percent from the county -wide 21
Century Community Learning Center Grant.
a. Bryan Rembold's salary was to be $60,000.00 per year (including benefits).
152. Rembold, as the WGSD superintendent, participated in securing the countywide 21
Century Community Learning Center Grant.
153. Effective September 19, 2001, Bryan Rembold's entire salary was funded by the
countywide 21 st Century Community Learning Center grant funds.
154. Bryan Rembold was compensated $56,146.14 by the vo -tech from the Greene County
Educational Consortium of which Rembold is a member and the financing of which was
obtained from a grant secured by Rembold.
The following findings relate to allegations that Rembold conducted private business
on school district time, using district equipment, district facilities, and district
materials
Work for King's Bridge, Incorporated:
155. Rembold submitted invoices to King's Bridge at various times detailing days, amount of
time, and rate of compensation for conducting research, writing, and data collection
relative to the PULSE program.
156. Rembold's invoices to King's Bridge Inc. were not date or time stamped indicating the
actual receipt by King's Bridge.
Rembold 01- 079 -C2
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157. Rembold performed services for King's Bridge on the same dates he was listed as
working as superintendent for WGSD.
158. Leave records from WGSD for Rembold and invoices submitted to King's Bridge Inc.
by Rembold confirm dates that when he was performing work for King's Bridge Inc. he
simultaneously was receiving compensation for working at the district and had no
recorded leave as follows:
a. 04 -09 -98 09 -07 -98
04 -10 -98 01 -14 -99
06 -03 -98 01 -15 -99
06 -15 -98 03 -18 -99
06 -16 -98 04 -02 -99
06 -17 -98 06 -12 -01
06 -18 -98 06 -13 -01
06 -19 -98
159. With regard to April 9th and 10 of 1998, Rembold avers that these dates represent the
Easter Holiday, per the West Greene School Calendar of 1997 -98.
160. With regard to the dates of June 15 through June 19 1998, these represented
vacation days.
161. September 7, 1998, represented the Labor Day Holiday as per the West Greene
School Calendar 1998 -99.
162. January 14 and 15 1999, were inclement weather /snow days, as confirmed by the
West Greene School Calendar 1998 -99.
163. March 18, 1999, represented a sick day as per leave records submitted to the Ethics
Commission in May, 2002.
164. April 2, 1999, represented the Easter Holiday as per the West Greene School
Calendar for 1998 -99. Please see Rembold's Exhibit "23" which is attached hereto
and made a part hereof.
165. On June 12 and 13 2001, Rembold worked during the school day with the West
Greene School District faculty and then worked during the evening hours, from 4:00
p.m. until midnight on the PULSE +3 Model. See Rembold's Exhibit "23"
166. Rembold did not utilize annual or personal leave from WGSD on June 3, 1998.
Work for Cabell County Board of Education:
167. Rembold assisted Steven Wilcox, Rembold's associate in King's Bridge, in presenting
peer counseling training for the Cabell County Board of Education at Camp Virgil Tate,
Route 4, Box 141 B, Charleston, WV 25312.
a. Wilcox presented the counseling training on the following dates:
Thursday, November 6, 1997, through Saturday, November 8, 1997.
Thursday, March 4, 1999, through Saturday, March 6, 1999.
Thursday, March 23, 2000, through Saturday, March 25, 2000.
Friday, March 9, 2001, through Sunday, March 11, 2001.
Rembold 01- 079 -C2
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168. Rembold assisted Wilcox during the 1999 and 2001 training sessions on the following
dates:
Thursday, March 4, 1998 Friday, March 9, 2001
Friday, March 5, 1999
169. Rembold did not utilize annual or personal leave from WGSD on Thursday, March 4,
1999; Friday, March 5, 1999; or Friday, March 9, 2001.
170. No leave was required to be taken by Rembold: March 4, 1998, represented a
inclement weather day as per the West Greene School Calendar 1997 -98.
171. March 5, 1999, was a vacation day as per the leave records.
172. March 9, 2001, Rembold worked a full day as Superintendent at the West Greene
School District. Rembold then traveled to CabeII County, West Virginia, and
conducted training activities beginning at 7:00 p.m. and worked on March la and 11'
2001, in Cabell County.
Work for Huntingdon Area School District:
173. Rembold has provided counseling /consultant services for the Huntingdon Area School
District, Huntingdon, Pennsylvania, since at least 1996.
a. Rembold was hired at the discretion of Huntingdon Area School District (HASD)
PULSE coordinator Arthur Waleski.
1. Waleski is employed as the assistant high school principal and PULSE
coordinator by HASD.
2. Waleski is also a compensated trainer for King's Bridge Inc.
174. Business records of the Huntingdon Area School District reflect Rembold received the
following compensation from that district during calendar years 1996, 1997, 1998, and
1999:
Transaction Check
Date No. Payee Amount Detail
11719796 0467$6 CP Rembold $1,629.30 Help -lin fining/
conference
04/22/97 048212 CP Rembold $1,834.40 Pulse Training
Coordinator
05/15/98 053107 CP Rembold $1,600.00 PULSE Camp
Consultant
05/18/99 057566 CP Rembold $1,573.20 3 Days Training and
Mileage
175. Rembold served as a trainer for a HASD PULSE retreat on April 7, 1999 through April
9, 1999.
176. Rembold did not utilize annual or personal leave from WGSD on April 7, 1999, April 8,
1999, or April 9, 1999.
177. Rembold was compensated by HASD for conducting training for HASD while
simultaneously receiving compensation from WGSD.
Rembold 01- 079 -C2
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a. Rembold was paid $812.64 by the WGSD while he was simultaneously paid by
HASD and did not utilize annual or personal leave.
b. Compensation for Rembold based on three (3) eight hour days in 1999 at
$33.86 per hour.
c. This training did not relate to Rembold's duties as superintendent at WGSD.
Use of WGSD Telephones:
178. WGSD Policy No. 710, Section: Property, Titled: Use of Facilities by Staff, was
adopted on November 18, 1991 and governed the use of district equipment, including
telephones and fax machines.
a. The policy is as follows:
1. Purpose: School equipment and facilities may not be used by district
staff for personal reasons, either on or off school property, without
explicit authorization or administrative permission in accordance with
these guidelines.
2. Authority: The facilities and equipment of the district are only available
for staff use if such is clearly within the authorization granted in a policy
of the Board or temporary approval has been granted by the
Superintendent.
The board specifically prohibits, except as authorized in the foregoing
paragraph, personal use of district telephones, materials, tools, supplies,
equipment, and district vehicles.
b. This policy was in effect throughout Rembold's tenure as superintendent at
WGSD.
179. Employees of the WGSD were not permitted to use district phones /fax equipment to
conduct personal business.
180. Rembold had access to general phone lines of the district while serving as
Superintendent of WGSD.
a. Rembold did not have a direct phone line assigned to him.
181. Rembold made personal /personal business calls using WGSD telephones.
a. Some of the calls and faxes were directly related to King's Bridge and /or
PULSE activities.
182. Rembold identified and made reimbursement to WGSD for making personal/ personal
business calls and faxes for the period of July 2000 through March 2001.
a. Rembold made this reimbursement on July 16, 2001 with personal check no.
2596 in the amount of $90.60.
183. Rembold made another reimbursement to the district for making personal calls in the
amount of $84.30 by personal check no. 2650 on September 18, 2001.
a. Rembold made this reimbursement for the estimated amount of personal/
personal business calls made from district telephones for the period of April
2001 through June 2001.
Rembold 01- 079 -C2
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184. The telephone numbers identified by Rembold as personal /personal business
associated with King's Bridge and PULSE included the following:
717 - 264 -1299 Edgar Thacker /King's Bridge
717 - 356 -2331 SCSD
570 - 672 -3869 Steve Wilcox
814 - 643 -1080 HASD
814 - 643 -3800 HASD -Fax
814 - 643 -1114 Mainstream Counseling
814 - 643 -5344 Mainstream Counseling -Fax
a. The other numbers on the list identified by Rembold as personal /personal
business are private numbers.
185. For the period from December 1998 through December 2000 Rembold made
personal /personal business telephone calls from WGSD telephones for which he made
no reimbursement in the total amount of $97.33.
186. Long distance toll records for WGSD confirm Rembold placing calls and faxes to
PULSE and King's Bridge associates and other personal calls /faxes on at least 271
occasions from May 1998 through December 2000.
a. These calls, were made by Rembold to Edgar Thacker, Steve Wilcox and
Arthur Waleski, and other PULSE and King's Bridge Associates.
b. These calls are separate from those Rembold had made reimbursement
payments to the district for.
187. Included with WGSD long distance toll records are toll charges to various locations
throughout the Commonwealth of Virginia.
188. In addition to placing calls to his PULSE and King's Bridge associates, Rembold
received calls at WGSD from Steve Wilcox, Edgar Thacker, Art Waleski, and Lonnie
Woomer.
a. All four (4) were connected to Rembold through PULSE and /or King's Bridge.
189. Approximately 300 calls were placed by Wilcox to Rembold at WGSD from October
1998 through May 2000 totaling 1,670.3 minutes and $149.30
a. These calls were placed during the same time Rembold was consulting with
Wilcox on PULSE/King's Bridge business.
190. Phone records of the Huntingdon Area School District confirm calls were placed to
Rembold at WGSD by Art Waleski from May 1995 through April 2001 at HASD
totaling 266.9 minutes and $25.74.
a. These calls were placed during the same time Rembold was consulting with
Waleski on PULSE.
191. Telephone records of Mainstream Counseling indicate that calls were placed by
Mainstream Counseling to WGSD while Rembold was employed as the district
superintendent.
a. These calls were placed at a time when Mainstream Counseling had a
partnership agreement with King's Bridge and when Rembold was including
Mainstream on grant applications.
Rembold 01- 079 -C2
Page 39
b. Calls were placed from Mainstream Counseling from May 1998 to August 29
2001 totaling 822.07 minutes.
192. Rembold also received and had faxes sent to Steve Wilcox/Southern Columbia
School District regarding Rembold's involvement with PULSE and /or King's Bridge
on several occasions.
193. Rembold's use of the telephone in relation to PULSE and /or King's Bridge related
activities, while on WGSD time, is as follows:
a. Personal calls placed by Rembold:
Time by school year:
2000 -2001 63.4 minutes (0.1 hours) [sic]
1999 -2000 568.3 minutes 9.5 hours
1998 -1999 364.1 minutes 6.1 hours
TOTAL: 995.8 minutes (16.7 hours)
Salary by school year:
2000 -2001 $ 40.68
1999 -2000 $ 336.21
1998 -1999 $ 206.55
TOTAL: $ 583.44
b. Personal calls received by Rembold from Southern Columbia School District:
Time by school year:
2000 -2001 923.4 minutes (15.4 hours
1999 -2000 466.2 minutes (7.8 hours
1998 -1999 281.7 minutes (4.7 hours
TOTAL: 1,671.3 minutes (27.9 hours)
Salary by school year:
2000 -2001 $ 569.50
1999 -2000 $ 276.04
1998 -1999 $ 159.14
TOTAL: $ 1,004.68
c. Personal calls received by Rembold from Huntingdon Area School District:
Time by school year:
2000 -2001 62.7 minutes 1.0 hours
1999 -2000 51.9 minutes 0.9 hours
1998 -1999 67.7 minutes 1.1 hours
1997 -1998 69.1 minutes 1.2 hours
TOTAL: 251.4 minutes (4.2 hours)
Rembold 01- 079 -C2
Page 40
Salary by school year:
2000 -2001
1999 -2000
1998 -1999
1997 -1998
TOTAL:
d. Personal calls received by Rembold from Mainstream Counseling:
Time by school year:
2000 -2001 115.7 minutes
1999 -2000 95.4 minutes
1998 -1999 292.5 minutes
1997 -1998 100.6 minutes
TOTAL: 604.2 minutes
Salary by school year:
2000 -2002
1999 -2000
1998 -1999
1997 -1998
TOTAL:
a. 2000 -2001: ( Salar y
Placing calls from
Receiving calls from
Receiving calls from
Receiving calls from
TOTAL:
b. 1999 -2000: ( Salar y
Placing calls from
Receiving calls from
Receiving calls from
Receiving calls from
TOTAL:
c. 1998 -1999: ( Salar y
Placing calls from
Receiving calls from
Receiving calls from
Receiving calls from
TOTAL:
d. 1997 -1998: (Salar
Receiving calls from
Receiving calls from
TOTAL:
$ 36.98
$ 31.85
$ 37.25
$ 38.88
$ 144.96
$ 70.26
$ 56.62
$ 165.91
$ 55.08
$ 347.87
- $36.98 /hour
WGSD: $
SCSD: $
HASD: $
MC: $
$
- $35.39 /hour
WGSD: $
SCSD: $
HASD: $
MC: $
$
- $33.86 /hour
WGSD: $
SCSD: $
HASD: $
MC: $
$
y - $32.40 /hour
m HASD: $
MS: $
(1.9 hours
1.6 hours
4.9 hours
1.7 hours
(10.1 hours)
194. Rembold received a private pecuniary gain of $2,080.95, as a result of transacting private
business using WGSD's telephone, during his work hours as superintendent:
40.68
569.50
36.98
70.26
717.42
336.21
276.04
31.85
56.62
700.72
206.55
159.14
37.25
165.91
568.85
38.88
55.08
93.96
Rembold 01- 079 -C2
Page 41
GRAND TOTAL: $2,080.95
The following findings relate to the allegation that Rembold submitted and received
duplicate expense reimbursements from West Greene School District and other
sources
195. In his capacity as WGSD Superintendent, Rembold received mileage reimbursement
for use of his vehicle while on official business.
a. Reimbursements would be made for each mile traveled.
b. Reimbursement rates were:
2000: .0325¢
2001: .0345¢
196. Expense reimbursement records on file with WGSD confirm Rembold received mileage
reimbursement for his attendance at PULSE training held in Elizabethtown, PA on
days that he was on leave from the district.
a. Rembold was not entitled to receive expense reimbursement from the district for
expenses incurred not related to official WGSD duties.
b. Rembold received mileage reimbursement on days when he was not working for
the school district.
197. Rembold's expense records submitted to WGSD included the following mileage
reimbursements for his attendance at PULSE trainings while on leave from the district:
a. Rembold received West Greene School District check number 22685 dated
February 12, 2001, in the amount of $3,661.73 that included $177.33 for 514
miles to PULSE training in Elizabethtown, PA on February 5, 2001 to February
8, 2001.
1. Leave records confirm Rembold took vacation leave on February 6, 7, 8,
2001.
2. Rembold was compensated at the rate of $0.345 per mile for this travel.
b. Rembold received WGSD check number 22959 in the amount of $403.95 that
included $128.00 for 370 miles to Elizabethtown, PA on April 3, 2001 and April
4, 2001.
1. Rembold took personal leave on April 3, 2001 and April 4, 2001, but was
also called back to West Greene School District for an emergency on
that date.
2. Rembold was compensated at the rate of $0.345 per mile for this travel.
c. Both reimbursements were for travel expenses related to King's Bridge and/ or
PULSE.
198. Rembold received reimbursement from both the WGSD and Southern Columbia
School District for travel expenses related to Rembold's independent consultant
activities.
Rembold 01- 079 -C2
Page 42
a. Rembold received WGSD check number 22095 in the amount of $202.33 that
included $195.00 for 600 miles roundtrip to SCSD on October 29 -30, 2000.
1. Rembold was compensated at the rate of $0.325 per mile for this travel.
b. Rembold received SCSD check number 22214 in the amount of $230.37 that
included $211.25 for 650 miles roundtrip to SCSD on October 29 -30, 2000.
1. Rembold was compensated at the rate of $0.325 per mile for this travel.
2. This payment was approved by Steve Wilcox, SCSD Superintendent.
199. Rembold received duplicate expense reimbursement for mileage from WGSD and the
Greene County Industrial Development Authority (GCIA), an entity which Rembold
serves as president for expenses related to authority business.
a. Rembold received West Green School District check number 22095 in the
amount of $202.33 that included $14.30 for 44 miles incurred on October 25-
26, 2000.
1. Rembold was compensated at the rate of $0.325 per mile for this travel.
b. Rembold was also compensated this amount from the GCIDA.
200. Rembold submitted mileage reimbursement and received payments for mileage
unrelated to WGSD business as follows:
Date Miles Amount
02/05/01 to 02/08/01 514 miles .345 /mile $177.33
04/03/01 to 04/04/01 370 miles .345/mile $128.00
10/29/00 to 10/30/00 600 miles .325 /mile $195.00
10/25/00 to 10/26/00 44 miles @ .325 /mile $ 14.30
Total $514.63
201. Rembold issued checks to the WGSD as reimbursement for mileage as follows:
a. Rembold reimbursed WGSD by personal check no. 2651 in the amount of
$653.31 for all mileage reimbursements made to him for travel to Southern
Columbia School District.
b. Rembold reimbursed the WGSD with personal check number 2655 in the
amount of $14.30 for this mileage.
The following findings relate to allegations regarding Rembold's failure to file
Statements of Financial Interests
202. Rembold, in his capacity as superintendent of WGSD was annually required to file
Statement of Financial Interests (SFI's) forms by May 1 of each year for the prior
calendar year.
203. Rembold failed to file SFI's for calendar years 2000, 1999, 1998, and 1997 by May 1
of the following year.
204. Statements of Financial Interests forms were annually mailed to the West Greene
School District in 1998, 1999, 2000, 2001, and 2002 by the Administrative Division of
the State Ethics Commission.
Rembold 01- 079 -C2
Page 43
a. In 1998, blank forms, SEC -1, Rev. 1/98 were mass mailed to all municipalities
in the Commonwealth, including LIU, on January 26, 1998.
b. In 1999 blank forms, SEC -1, Rev. 1/99, were mass mailed to all municipalities
in the Commonwealth, including LIU, on February 9, 1999.
c. The 2000 forms SEC -1, Rev. 1/00 were bulk mailed to all municipalities in the
Commonwealth, including LIU, on January 21, 2000.
d. The 2001 forms SEC -1, Rev. 1/01 were bulk mailed to all municipalities in the
Commonwealth, including LIU, on or about December 29, 2000.
e. The 2002 forms SEC -1, Rev. 1/2002 were bulk mailed to all municipalities in
the Commonwealth, including LIU, on or about December 14, 2001.
205. In 2000, 2001 and 2002, blank Statement of Financial Interests forms were mailed by
the State Ethics Commission to the West Greene School District addressed to Charles
Rembold, Superintendent, 1367 Hargus Creek Road, Waynesburg, PA 15370.
a. In 1999 and 1998 blank Statements of Financial Interests forms were mailed by
the State Ethics Commission to the West Greene School District, addressed to
Charles Rembold, Superintendent, R.D. #5, Box 36B, Waynesburg, PA
15370.
b. Blank Statements of Financial Interests were forwarded directly by the State
Ethics Commission to Rembold in his position as West Greene School District
Superintendent since at least 1998.
206. The clerical staff channeled the mailed Statement of Financial Interests to the business
manager.
207. The material that was forwarded to Rembold by the State Ethics Commission each
year not only included the blank Statements of Financial Interests forms but also
included a cover memo advising of the filing requirement procedures and deadlines.
208. Prior to late winter /early spring 2001, SFI's were only distributed to school board
members and the solicitor by the district business administrator.
209. The business manager of the West Greene School District did not circulate the forms
to any administrator, including Rembold.
210. No administrator in the history of the West Greene School District ever completed the
Statement of Financial Interests prior to the Spring of 2001.
211. In or around March /April 2001, the business administrator learned that other
personnel, including the superintendent, were required to file SFI's.
a. The business administrator consulted the district solicitor who verified that
administrators, including the superintendent, were required to file SFIs.
212. After consulting with the solicitor, the business administrator informed Rembold that he
and other administrators were required to file SFIs.
213. Rembold did not file any SFIs with the WGSD prior to resigning in August 2001.
214. Rembold completed SFIs for calendar years 2001, 2000, 1999, 1998, and 1997 on
February 6, 2002, and filed them at the WGSD on May 1, 2002.
Rembold 01- 079 -C2
Page 44
215. Rembold had never been advised either by the solicitor or by the West Greene School
District Business Manager as to the requirement of annually filing a statement of
financial interest.
216. Rembold eventually filed SFIs at the WGSD disclose information as follows:
a. 2001:
b. 2000:
c. 1999:
d. 1998:
Real Estate Interests:
Creditors:
Direct /Indirect sources of Income:
Gifts:
Transportation, Lodging, Hospitality:
Office, Directorship, Employment
in any Business:
Financial Interest in any Business:
Business Interests Transferred:
Real Estate Interests:
Creditors:
Direct /Indirect sources of Income:
Gifts:
Transportation, Lodging, Hospitality:
Office, Directorship, Employment
in any Business:
Financial Interest in any Business:
Business Interests Transferred:
Real Estate Interests:
Creditors:
Direct /Indirect sources of Income:
Gifts:
Transportation, Lodging, Hospitality:
1999 (continued)
Office, Directorship, Employment
in any Business:
Financial Interest in any Business:
Business Interests Transferred:
Real Estate Interests:
Creditors:
None
None
West Greene SD
Jefferson - Morgan SD
King's Bridge Inc.
None
None
Independent Contractor
Kings Bridge Inc.
Research Writer Facilitator
None
None
None
None
West Greene SD
King's Bridge Inc.
None
None
Independent Contractor
Kings Bridge Inc.
Research Writer Facilitator
None
None
None
None
West Greene SD
Huntingdon SD
King's Bridge Inc.
None
None
Independent Contractor
Kings Bridge Inc.
Huntingdon SD
Research Writer Facilitator
None
None
None
None
Rembold 01- 079 -C2
Page 45
e. 1997:
a.
Direct /Indirect sources of Income:
Gifts:
Transportation, Lodging, Hospitality:
Office, Directorship, Employment
in any Business:
Financial Interest in any Business:
Business Interests Transferred:
Real Estate Interests:
Creditors:
Direct /Indirect sources of Income:
Gifts:
Transportation, Lodging, Hospitality:
Office, Directorship, Employment
in any Business:
Financial Interest in any Business:
Business Interests Transferred:
f. All of the forms filed by Rembold were dated February 6, 2002.
217. Rembold failed to disclose information on his Statements of Financial Interests as
follows:
2001:
Office, Directorship, Employment
in any Business:
b. 2000:
Office, Directorship, Employment
in any Business:
c. 1999:
Office, Directorship, Employment
in any Business:
West Greene SD
Huntingdon SD
King's Bridge Inc.
Greene Co. Vo -Tech
None
None
Independent Contractor
Kings Bridge Inc.
Huntingdon SD
Research Writer Facilitator
None
None
None
None
West Greene SD
Huntingdon
King's Bridge Inc.
Greene Co. Vo -Tech
None
None
Independent Contractor
Kings Bridge Inc.
Research Writer Facilitator
None
None
- Greene County Industrial
Development Corp.
- Evergreene Technology Park, Inc.
- A Community Agile Partners in
Education.
- Greene County Industrial
Development Corp.
- A Community Agile Partners in
Education.
- A Community Agile Partners in
Education.
218. Rembold asserts that he was unaware that he was required to file information regarding
his application with non - profit entities.
III. DISCUSSION:
Rembold 01- 079 -C2
Page 46
At all times relevant to this matter, the Respondent, Charles Rembold, hereinafter
Rembold, has been a public official subject to the provisions of the Public Official and
Employee Ethics Law, Act 9 of 1989, Pamphlet Law 26, 65 P.S. § 401, et se as codified by
the Public Official and Employee Ethics Act, Act 93 of 1998, Chapter 11, 65Pa.C.S. § 1101
et seq., which Acts are referred to herein as the "Ethics Act."
The allegations are that Rembold, as the Superintendent for the West Greene School
District (WGSD), violated Sections 3(a)/1103(a), 3(f)/1103(f) and 4(a)/1104(a) of the Ethics
Act when he participated in discussions and actions of WGSD resulting in its implementation
of the PULSE program (People Utilizing Leadership Skills Effectively), and the acquisition of
grant funds to pay for the PULSE program when he was an employee/ director of King's
Bridge Inc. (King's Bridge), which developed and owned the copyright for the PULSE program
and which received payments for use of the PULSE program; when the contract with King's
Bridge, was entered into without an open and public process; when he participated in the
administration of the district's contract /subcontract with King's Bridge; when he submitted and
received duplicate expense reimbursements from WGSD, Southern Columbia School District
(SCSD) and King's Bridge for the same expenses related to King's Bridge business; when he
conducted King's Bridge business on district time using school district facilities, equipment and
supplies; when he secured grant funding for a technology coordinator position that he
developed for his son and for which his son was ultimately hired to fill; and when he failed to
file Statements of Financial Interests (SFI's) for the 1997, 1998, 1999 and 2000 calendar
years.
Pursuant to Section 3(a)/1103(a) of the Ethics Act, a public official /public employee is
prohibited from engaging in conduct that constitutes a conflict of interest.
The term "conflict of interest" is defined under Act 9 of 1989/Act 93 of 1998 as follows:
Section 2/1102. Definitions
"Conflict" or "conflict of interest." Use by a public official
or public employee of the authority of his office or employment or
any confidential information received through his holding public
f
of ce or employment for the private pecuniary benefit of himself,
a member of his immediate family or a business with which he or
a member of his immediate family is associated. "Conflict" or
"conflict of interest" does not include an action having a de
minimis economic impact or which affects to the same degree a
class consisting of the general public or a subclass consisting of
an industry, occupation or other group which includes the public
official or public employee, a member of his immediate family or a
business with which he or a member of his immediate family is
associated.
65 P.S. § 402/65 Pa.C.S. § 1102.
Section 3(a)/1103(a) of the Ethics Act prohibits a public official /public employee from
using the authority of public office /employment or confidential information received by holding
such a public position for the private pecuniary benefit of the public official /public employee
himself, any member of his immediate family, or a business with which he or a member of his
immediate family is associated.
Section 3(f)/1103(f) of the Ethics Act provides:
Section 3/1103. Restricted activities
(f) No public official or public employee or his spouse
or child or any business in which the person or his spouse or
Rembold 01- 079 -C2
Page 47
child is associated shall enter into any contract valued at $500 or
more with the governmental body with which the public official or
public employee is associated or any subcontract valued at $500
or more with any person who has been awarded a contract with
the governmental body with which the public official or public
employee is associated, unless the contract has been awarded
through an open and public process, including prior public notice
and subsequent public disclosure of all proposals considered and
contracts awarded. In such a case, the public official or public
employee shall not have any supervisory or overall responsibility
for the implementation or administration of the contract. Any
contract or subcontract made in violation of this subsection shall
be voidable by a court of competent jurisdiction if the suit is
commenced within 90 days of the making of the contract or
subcontract.
65 P.S. § 403(f)/65 Pa.C.S. § 1103(f).
Section 3(f)/1103(f) of the Ethics Act provides in part that no public official /public
employee or spouse or child or business with which he or the spouse or child is associated
may enter into a contract with his governmental body valued at five hundred dollars or more or
any subcontract valued at five hundred dollars or more with any person who has been
awarded a contract with the governmental body with which the public official /public employee
is associated unless the contract is awarded through an open and public process including
prior public notice and subsequent public disclosure.
Section 4(a)/1104(a) of the Ethics Act requires that each public official /public employee
must file an SFI for the preceding calendar year, each year that he holds the position and the
year after he leaves it.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are reproduced above as the Findings of this
Commission. We shall now summarize the relevant facts as contained therein.
Rembold was employed as WGSD Superintendent from July 1, 1993, until
August 20, 2001, when he resigned to accept a position as the superintendent of the
Jefferson- Morgan School District where he is currently employed.
In a private capacity, Rembold has been involved with King's Bridge, a Virginia corporation
that offers training programs for schools, businesses, government ,and police, since at least July
1983. Rembold served as an initial director of the corporation, continued as a listed director on the
corporation papers until 2001, and served as a consultant/ contractor providing training programs,
research and other services. One of the programs developed by King's Bridge for school districts
focused on at -risk students. King's Bridge holds the copyright for the PULSE Program which is the
cornerstone of the training programs.
King's Bridge filed articles of incorporation with the Virginia State Corporation
f
Commission on July 28, 1983, which identified Rembold as one of two shareholders. On
March 8, 1993, R. Edgar Thacker filed an annual report with the Virginia Corporation
Commission that included corporate officers and directors as follows: Charles P. Rembold,
President /Director; R. E. Edgar Thacker, Secretary /Director; Carla Watson, Director; and
Steven Wilcox, Director. Rembold was formally listed as a president /corporate director in
annual reports for the years 1994 through 2000. By letter of February 17, 1993, Rembold
resigned as president and stockholder in King's Bridge Inc. A report filed on June 1, 2001,
lists the removal of Charles P. Rembold and Michael Stephen Wilcox as corporate officers
and /or directors.
Rembold 01- 079 -C2
Page 48
In about 1991, PULSAR, Inc. offered a training program package under the program
name PULSAR to public entities in Virginia. The PULSE concept was developed by Rembold,
Thacker, and Wilcox. PULSAR was similar conceptually to the PULSE program developed by
King's Bridge. PULSAR, Inc. was incorporated with the Virginia State Corporation
Commission on April 15, 1991. Original incorporators were G. L. Wells, Charles Rembold,
and Edgar Thacker. The stated purpose of the corporation was to educate the public,
students, educators, and law enforcement officials and to increase their awareness of the
causes, the dangers and problems, and the method of dealing with students at -risk, including
low self- esteem students suffering from depression, truant students and juvenile offenders.
Rembold was not listed as a corporate officer or director on any annual reports filed by
PULSAR. In about 1994, philosophical differences occurred among the PULSAR directors.
Michael Steven Wilcox, one of the PULSE originators and a listed director of King's Bridge,
suggested to Walter Brown, the chairman of PULSAR, that it could serve as a "pass through"
of funds for King's Bridge. Wilcox's idea of increasing revenues for King's Bridge was that
PULSAR keep 10% of the consulting revenues generated while turning over or "passing
through" the balance of the funds to King's Bridge. Brown objected to this arrangement.
PULSAR continues to operate primarily in the Commonwealth of Virginia without the
involvement of Rembold, Wilcox, or Thacker. Rembold does not contest that Brown testified
as to the foregoing. Rembold asserts that he was unaware of the conversation. Following the
split from the PULSAR group, King's Bridge continued to operate and provide the PULSE
program.
In November of 1993, Arthur Waleski became employed as an Assistant High School
Principal by the Huntingdon Area School District (HASD), Huntingdon, Pennsylvania.
Waleski was familiar with Rembold, Wilcox, and Thacker, all of whom had been previously
employed in the Fairfax County, Virginia, school system. Waleski knew of the PULSAR
program as a result of serving as Assistant Principal at R. E. Lee High School in Staunton,
Virginia where Waleski worked under the supervision of Rembold. HASD utilized the services
of Mainstream Counseling, owned by Lonnie Woomer (Woomer), to perform drug and alcohol
counseling services. Waleski was interested in setting up a PULSE program at HASD.
Woomer was introduced to Rembold, Wilcox, and Thacker. From the spring of 1995 through
2001, the time period Woomer was associated with King's Bridge, she was under the
impression that Rembold, Wilcox, and Thacker were the principals of King's Bridge.
After learning of Woomer's /Mainstream Counseling's drug and alcohol services, Rembold
wanted Mainstream to be used for programs at WGSD. During 2000 and 2001, King's Bridge
utilized Mainstream Counseling in relation to the provision of services to WGSD. King's Bridge
asked Woomer of Mainstream Counseling if it would be listed at the top of the PULSE organizational
chart. The chart depicted Mainstream Counseling as receiving funding through grants and
contracting with King's Bridge for program marketing, development, management, implementation,
and evaluation. King's Bridge, in turn, would contract with the PULSE core training staff, as
independent contractors, which included Rembold, Wilcox, Thacker, Waleski, Woomer, and others.
Mainstream would be used as the entity to contract with local entities and then contract with King's
Bridge to provide services.
A meeting was held among Rembold, Thacker, Wilcox, Waleski, and Woomer, to
discuss Mainstream Counseling's affiliation with King's Bridge. Woomer was under the
impression that Rembold, Wilcox, and Thacker were acting on behalf of King's Bridge. During
the meeting, Rembold suggested using the services of Mainstream Counseling at SCSD and
WGSD. Rembold was superintendent at WGSD and Wilcox was superintendent at SCSD at
the time. Woomer informed Rembold, Wilcox, and Thacker that she was willing to enter into a
business relationship with King's Bridge to officially provide these services on two conditions:
(1) a signed contract between Mainstream Counseling and King's Bridge and; (2) both
Rembold and Wilcox not be on the board of directors and not have any ownership interest in
or names on any paperwork for King's Bridge. Woomer had concerns with Rembold and
Wilcox being affiliated with King's Bridge while contracting with their school districts. Both
Rembold 01- 079 -C2
Page 49
Rembold and Wilcox agreed to have their names removed as directors of King's Bridge. On
December 1, 1999, bloomer d /b /a Mainstream Counseling, Inc. entered into a one -year
professional services contract with King's Bridge effective January 1, 2000. King's Bridge was
identified as the consulting company for PULSE services. The terms and conditions of the
agreement are delineated in Fact Finding 35.
The above arrangement was used primarily with WGSD and on one occasion with
SCSD where school board members began to question Wilcox's affiliation with King's Bridge.
On at least four occasions between January 2000 and February 2001, Rembold advised
Woomer that he and Wilcox resigned from King's Bridge but Rembold and Wilcox remained as
listed directors for King's Bridge until June 1, 2001. King's Bridge had been an inactive
company between 1996 and 1999 when Rembold, Wilcox, and Thacker developed the
PULSE program for use in Pennsylvania school districts. The PULSE program was actively
marketed by Rembold and Wilcox after they became established as school district
superintendents in WGSD and SCSD.
Rembold, as WGSD superintendent, oversaw the daily operation of the district's
schools, teachers, and administrators; prepared board meeting topic and agenda items; and
identified, applied for and secured grant funding. Rembold was not required to obtain board
approval to seek grant funding. Beginning with his hiring as WGSD superintendent in July
1993, Rembold participated in the development of the PULSE program for WGSD. Rembold
oversaw the preparation and submission of grant applications which identified the PULSE
program and providers /contractors as King's Bridge and /or Mainstream Counseling. WGSD
did not have a PULSE program prior to Rembold's tenure as superintendent. After the WGSD
Board was provided with information by Rembold on the PULSE program and grant funding
for the program, the board was supportive of the district's involvement in the program. The
district's PULSE program included training for teachers, administrators and staff, educational
services and PULSE retreats for students with funding from state and federal grants and in-
kind contributions by the district. Rembold had oversight over all aspects of the district's
PULSE program. Minutes from the WGSD School Board of Directors which include the
discussions and information furnished to the board by Rembold and others on the district's
PULSE program and related funding are delineated in Fact Finding 47.
The WGSD Board passed a motion to contract with Mainstream Counseling, Inc. to
train a 10- person Elementary School team for the Elementary PULSE Program. Program,
materials, training services, registration, rooms, and meals could not exceed $9,000.00 to be
paid from a Crime and Delinquency Grant. Rembold was present for this meeting. On
September 28, 2000, Rembold informed the school board that the school district would receive
two grants, each in the amount of $150,000.00, to be partly used to coordinate the PULSE
Program at all three levels.
The WGSD Board also passed a motion to create the position of Middle School Drug
Prevention and School Safety Program Coordinator to be funded by the Safe /Drug Free
School Program Grant on a trial basis, subject to elimination after a three -year trial period if the
Middle School Drug Prevention and School Safety Program would be determined b the board
to be ineffective. The school board also passed a motion to contract with Mainstream
Counseling, Inc., to train a second Middle School team for the Middle School PULSE
Program. Program, materials, training services, registration, rooms, and meals could not
exceed $9,000.00 to be paid for from the Safe and Drug Free Schools Program Grant. On
November 16, 2000, Rembold informed the board that a PULSE Retreat was held on
November 6, 7, and 8. On May 17, 2001, Rembold informed the school board during a
Personnel Committee meeting that he would not be seeking another contract and started ajob
search for another superintendent position.
At Rembold's direction, WGSD applied for and received grant funds from PDE Safe &
Drug Free Schools program; Safe Schools Initiative; the PA State Commission on Crime &
Delinquency (PCCD); 1Drug Education /Law Enforcement Grant Program; and the U. S.
Rembold 01- 079 -C2
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Department of Education, 21 Century Community Learning Center Grant. Rembold
participated in applying for each of the grants by overseeing the preparation of grant
applications, determining costs, and identifying the PULSE program to be used. Each grant
applied for and received by WGSD consisted of state or federal funds which were distributed
by PDE and PCCD. Numerous grants applied for during Rembold's tenure as WGSD
superintendent included utilization of the PULSE program and Mainstream Counseling or
King's Bridge. Rembold was instrumental in identifying and implementing the PULSE program
while formally listed as a director and acting as a compensated independent contractor for
King's Bridge. From 1998 to 2001, Rembold, in his official capacity as WGSD
superintendent, participated in securing a total of ten separate grants from PDE, the PCCD,
and the U. S. Department of Education which included proposed funding for PULSE.
Rembold's participation in securing grant funding for the district's PULSE program
included oversight of the grant application process and identification of potential funding
sources at the federal, state, and local levels; contractors, consultants, and non - profit and
other governmental bodies to be used in connection with the grants; and programs to be
implemented and their costs. The only contractor /consultant utilized by Rembold for PULSE
training was Mainstream Counseling. Rembold participated in writing PULSE/ King's Bridge
Services into grant applications. WGSD did not have a PULSE program prior to Rembold.
Rembold participated in identifying the types of goods and services for which grant monies
were requested. Rembold approved the content of grant applications. Rembold directed
district teachers and administrators to assist in implementing the PULSE program and
arranged for PULSE services to be provided. Rembold verified the receipt of services relating
to the PULSE programs which resulted in the processing of the payment of all Mainstream
Counseling invoices that the school district board of directors subsequently approved.
Rembold was the source of the raw data and budget figures needed to complete the grant
applications.
On August 16, 1999, PCCD received a Pennsylvania Drug Education /Law
Enforcement Grant Program application in the amount of $16,121.00 from WGSD. The
application was submitted by Rembold. The project title was PULSE with Rembold listed as
the district's contact person. Rembold signed the grant agreement in his official capacity as
superintendent on August 16, 1999. Rembold signed a related consortium participation
agreement in his official capacity as superintendent on the same date. The program
objectives, as approved by Rembold, included the implementation of a PULSE programfor60
at -risk students in grades 7 -12, the training of 10 WGSD /community members as PULSE
facilitators, a three -day student /adult retreat, and maintenance of a PULSE club.
On January 27, 2000, PCCD forwarded the grant to WGSD for the district's approval.
Rembold, on behalf of the school district, signed the grant acceptance statement in the
amount of $16,121.00 for the "PULSE Program" project. Rembold's signature represented
that he agreed to accept on behalf of the district the grant "on the condition that you comply, in
administering your program, with all representations contained in your application as amended
and with the enclosed standard sub -grant conditions of the Commission.' PCCD then issued
payment to WGSD totaling $16,121.00. WGSD did not seek any competitive bids for the
PULSE program portion of this grant. Rembold participated in the decision to utilize the King's
Bridge's PULSE program as part of this grant. During this time period when Rembold took
actions regarding this grant, Rembold was an independent contractor paid by King's Bridge,
and was formally listed as a director of King's Bridge Incorporated. The WGSD Board of
Directors did not take any official action approving the submission of the PCCD $16,121.00
grant application.
On December 5, 1997, PDE sent notification to Rembold at WGSD of the availability of
funds from the Safe & Drug Free Schools Program. On April 17, 1998, WGSD received
notification that it would be allocated $6,101.00 provided it submitted a completed application
to PDE by July 1, 1998. WGSD received the grant of $6,101 00 from PDE for the 1998 -1999
allocation period. Rembold participated and had oversight responsibilities for the following
Rembold 01- 079 -C2
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actions with respect to the $6,101.00 Safe & Drug Free Schools 1998 -1999 grant program:
completion and submission of a detailed grant contract that included PULSE, a program
administered by King's Bridge; selection of PULSE training for district employees; approval of
grant expenditures; identification of district staff to be used; signed letters of assurance with
local law enforcement agencies; and signed the final grant completion report.
On November 18, 1998, PDE's Bureau of Community and Student Services sent
notification to Rembold as superintendent advising of funding available for the federal Safe
and Drug Free Schools and Communities Act Fund for 1999/2000. On May 7, 1999,
Rembold was advised that WGSD's allocation was $5,032.00. On June 29, 1999, Rembold,
in his official capacity of superintendent, signed the grant application for the 1999 -2000 PDE
grant. Included with the application was a reference to WGSD's intent to utilize the grant
funds to support the district's PULSE program. Rembold received notification of approval of
this grant from PDE on February 17, 2000. Members of the WGSD Board of Directors signed
the grant application as members of the Safe and Drug Free Schools and Community
Advisory Council. Rembold, as superintendent, participated in or had oversight responsibilities
for the following actions with respect to the $5,032.00 Safe & Drug Free Schools 1999 -2000
grant program: identification of the funding source; the district's contact person; completion of
the grant application which identified use of the PULSE Program; completion of progress
reports adjusting budget figures; approval of budget expenditures which include PULSE
program fees; and identification of staff to be used to complete the grant.
In December 1999, Rembold received notification from PDE regarding funding from the
federal Safe & Drug Free Schools and Communities Act funds for 2000/2001. Rembold, as
superintendent, signed the grant application seeking funds for the 2000 -2001 grant period.
Rembold requested funding totaling $4,825.00. Included with the application is a program
narrative detailing a PULSE survey and PULSE program, with no mention of King's Bridge.
Rembold received notification of the grant approval on or about May 10, 2000, and the grant
was then paid to the district. Rembold participated in or had oversight responsibilities for the
following actions with respect to the $4,825.00 Safe & Drug Free Schools and Communities
2000 -01 grant program: identification of the funding source, completion of the grant
application and signature; the district contact person; and identification of staff to be used to
complete this grant.
Rembold submitted a district grant application to PDE, Office of Safe Schools, Bureau
of Community and Student Services, with his name as contact person on May 11, 1999, for
the 1999/2000 safe schools initiative. This grant application was in the amount of $20,000.00
with the district contributing matching funds of $31,011.00 for total project costs of
$51,011.00. Rembold completed the grant application for submission to PDE with himself as
superintendent as the contact person. Rembold stated in the grant application that the
purpose for obtaining the grant was to enable WGSD to implement a PULSE Program as a
prevention /intervention to meet the needs of adolescents who are at high risk toward
unhealthy behaviors. The application sought to utilize the PULSE program developed by
King's Bridge. Design and operation of the program was to implement a PULSE Program from
July 1, 1999, through June 30, 2000, as a prevention /intervention, school- based, community
inclusive program designed to address the needs of adolescents who are at high -risk toward
unhealthy behaviors. The grant application submitted by Rembold specified that WGSD
would contract with King's Bridge to implement a PULSE Program described as being
developed over a twenty -year period with its roots firmly planted in substance abuse
prevention, intervention, and community action planning.
On October 25, 1999, Rembold signed a letter of agreement with the Central
Susquehanna Intermediate Unit securing a $20,000.00 grant. Rembold participated in or had
oversight responsibility for the following actions with respect to the district's $20,000.00 Safe
Schools Initiative Grant program for 1999 -2000: identification of the funding source and
preparation of the application; identification of the consultants, including King's Bridge;
identification of the services to be provided, including King's Bridge's PULSE program;
approval of the grant budget; identification of the district staff to be used; the district contact
Rembold 01- 079 -C2
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person; completion of and submission of the grant application; and approval of grant
expenditures, including fees for King's Bridge and /or the PULSE program.
Rembold submitted a WGSD district grant application to PDE, Office of Safe Schools,
Bureau of Community and Student Services, on September 23, 1999, for the 1999 -2000 Safe
Schools Initiative grant program. This grant request was in the amount of $50,000.00 with the
district contributing matching funds of $36,828.00 for total project costs of $86,828.00. The
grant application listed contractors /consultants including King's Bridge to implement a PULSE
program. Rembold was specifically identified as being responsible for implementing a PULSE
program for 120 "at- risk" students in grades 4 -8 to encourage appropriate decision making
through prevention and intervention activities. On December 7, 1999, Rembold was notified
by PDE that only a $26,400.00 grant was awarded. On December 15, 1999, Rembold
submitted a revised budget to PDE due to the reduction in grant funding. Rembold signed a
letter of agreement with the Central Susquehanna Intermediate Unit accepting the $26,400.00
grant awarded on February 11, 2000, which was followed by the receipt of the grant funds.
Rembold participated in or had oversight responsibilities for the following actions with
respect to the district's $26,400.00 Safe Schools Initiative grant program for 1999 -2000:
identification of the funding source; identification of consultants and vendors to be used,
including King's Bridge; identification of services to be provided, specifically the PULSE
program; inclusion of King's Bridge for PULSE training into the grant; fixing and approval of
the grant budget which included fees to be paid to Kings Bridge and /or PULSE; identification
of district staff to be used; the district contact person; completion and submission of the grant
application and budget revisions; signature of grant agreement letters; and approval of grant
expenditures for King's Bridge. Rembold oversaw the administration of this grant in his official
capacity as WGSD superintendent while simultaneously receiving compensation by King's
Bridge as an independent contractor during the time period when he used the authority of his
position to ensure King's Bridge's /PULSE program was used.
In addition to grant funding requested from Pennsylvania, Rembold, as the WGSD
superintendent, applied for grant funding from the U. S. Department of Education WGSD
secured three grants from the U. S. Department of Education, including two 21 Century
Community Learning Center (CCLC) grants. Rembold oversaw the submission of an
application to the U. S. Department of Education for a CCLC grant for the WGSD Middle
School. The application prepared by Rembold sought total federal funding of $268,297.00.
Rembold signed the application for WGSD on February 24, 1999. The grant application
provides that PULSE would be utilized for youth development activities. Rembold was
identified in the application as a creator of PULSE. Rembold was formally listed as a director
of King's Bridge at the time of this grant and received compensation from King's Bridge.
Rembold's first payment as an independent contractor for King's Bridge Incorporated was
received on January 25, 2000. The grant application had been submitted prior to the
payment.
The Greene County Educational Consortium, of which Rembold was a member,
submitted a second application to the U. S. Department of Education for a county -wide CCLC
grant in the amount of $2,650,917.00 for three years. Rembold signed the application for
WGSD on March 20, 2000. Program Costs included specific PULSE expenses. Rembold
was formally listed as a director of King's Bridge at the time of this grant and was receiving
compensation from King's Bridge.
Rembold oversaw the submission of another application to theU. S.Department of
Education for the hiring of a Middle School Drug Prevention and School Safety Program
Coordinator. The application sought total federal funding of $198,598.00 for three years.
Rembold signed the application for WGSD on May 10, 2000. This grant application was
submitted to support PULSE activities. Rembold was formally listed as a director of King's
Bridge at the time of this grant and was receiving compensation from King's Bridge.
Mainstream Counseling was utilized by King's Bridge to contract with WGSD for PULSE
related services in relation to grants received by WGSD, including Safe Schools Initiative,
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Safe & Drug Free Schools, and U. S. Department of Education. Mainstream Counseling
invoiced and received $46,033.13 [sic] from WGSD for PULSE related services associated
with the Safe Schools Initiative, Safe and Drug -Free Schools, and U. S. Department of
Education Grants as delineated in Fact Finding 111. Payments were made directly to
Mainstream Counseling and charged to Safe Schools Initiative, Safe and Drug -Free Schools,
and U. S. Department of Education Grants. Rembold, as superintendent, authorized
submission of all of the payments from Mainstream Counseling to the WGSD Board for
approval.
Mainstream Counseling invoiced and received $98,000.00 by GCVT for PULSE
related services associated with the U. S. Department of Education Grants as delineated in
Fact Finding 115. Payments were made directly to Mainstream Counseling and charged to
Safe Schools Initiative, Safe and Drug -Free Schools, and U. S. Department of Education
Grants. WGSD and GCVT paid Mainstream a total of $144,033.13 for services related to the
PULSE program. Rembold participated in negotiating the agreement as a representative of
King's Bridge with WGSD. Rembold had no involvement with Mainstream Counseling, Inc.'s
services to GCVT. Rembold was formally listed as a director of King's Bridge during the entire
time he was administering grants and authorizing payments to Mainstream Counseling and
receiving compensation as an independent contractor to conduct King's Bridge training during
this period and for developing the Middle School PULSE Model, the PULSE +3 Model for
adjudicated youth, and the development of a rural economic development strategy for rural
communities. Mainstream issued payments totaling $136,900.00 to King's Bridge for PULSE
related services provided to WGSD and GCVT in connection with the Safe Schools Initiative,
Safe and Drug -Free Schools, and U. S. Department of Education Grants as delineated in
Fact Finding 119.
Rembold was formally listed as a director of King's Bridge and was employed by King's
Bridge as an independent contractor during the entire time he was administering grants and
authorizing payments to King's Bridge and Mainstream Counseling. Rembold oversaw the
inclusion of the services provided by King's Bridge and Mainstream Counseling into grant
applications he submitted. Rembold's actions securing Safe Schools Initiative, Safe and
Drug -Free Schools, andU. S.Department of Education grants resulted in private pecuniary
gains to King's Bridge of $136,900.00. During the period when Rembold was taking actions
as WGSD Superintendent relating to the award of contracts to King's Bridge and /or
Mainstream Counseling, and the obtaining grants relative to services rendered by these
entities, he received payments totaling at least $27,795.00 from January 2000 through July
10, 2001, from Kings Bridge. These payments were related to program development and
trainer /consultant services development of the PULSE +3 model, the middle school model and
the rural economic development model provided by Rembold in relation to PULSE programs
and King's Bridge activities with school districts.
Rembold's first payment from King's Bridge Inc., on January 25, 2000, occurred
approximately two weeks after the first training for WGSD was completed on January 11 -13,
2000. Rembold had never received any funds from King's Bridge prior to the time that King's
Bridge did business with WGSD. All payments to Rembold, Wilcox, Waleski and the other
PULSE Core Training staff came from the King's Bridge bank account. Payments issued to
Rembold from King's Bridge did not begin until after King's Bridge received payments from
WGSD, SCSD, and HASD. King's Bridge Inc., was a dormant company from January 1996
until January 2000 maintaining an account balance of approximately $3,117.59. The King's
Bridge accounts showed increased deposits and withdrawals following the acquisition of
contracts with WGSD. Funds received by King's Bridge from WGSD, SCSD, and HASD
comprised the majority of the deposits into King's Bridge accounts. King's Bridge did not
appear as a vendor of WGSD because of its agreement with Mainstream Counseling whereby
it submitted all bills relating to the provision of PULSE services to WGSD on behalf of King's
Bridge. Mainstream Counseling was identified as the service provider on applications/budgets
when obtaining grants even though the actual provider would be King's Bridge. Mainstream
Counseling provided no services to WGSD in relation to PDE, PCCD, and U. S. Department
Rembold 01- 079 -C2
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of Education Grants. Mainstream Counseling's only service was to submit invoices to
WGSD. Mainstream Counseling deducted 5% of the total as administrative costs and
forwarded the balance to King's Bridge.
Separate and apart from the above, GCVT receives funding and provides services for
the five school districts in Greene County. Rembold is not employed by the Vo -Tech. The
WGSD is one of the school districts covered by GCVT. The vo -tech is governed by a five -
member Joint Operating Committee (JOC) comprised of one school board member from each
of the five school districts. A director supervises the daily activities of the vo -tech. The vo-
tech also has a superintendent of record who is a superintendent from one of the five county
school districts. The superintendent of record serves as the superintendent of the vo -tech,
chairs JOC meetings, and acts as the director in the director's absence.
Bryan, Rembold's son, was employed by the GCVT as a technology coordinator since
July 1, 2000. Bryan served as an intern for the vo -tech during the summer months in 1999
and 2000 prior to being hired as a regular employee of the vo -tech. By letter dated January
26, 2001, Rembold informed JOC of the Vo -Tech that the WGSD Board approved funding for
the technology coordinator, and requested that his son be hired for this position. JOC
reassigned Bryan to this position effective March 1, 2001. At the time JOC reassigned Bryan,
Rembold was the immediate supervisor of two of the members of JOC in their capacity as
teachers at WGSD. Bryan Rembold resigned as the technology coordinator for the West
Greene Middle School on April 18, 2001. Bryan Rembold was compensated $3,786.92 by the
vo -tech from the Greene County Educational Consortium, of which Rembold was a member,
with financing from a grant secured by Rembold.
From April 18, 2001 until June 10, 2001, Bryan remained an employee of the vo -tech
as a technology coordinator for four hours per day funded solely by the vo -tech. Effective
June 11, 2001, JOC reassigned Bryan to work eight hours per day for the vo -tech and for four
school districts in the county (except West Greene) that was funded fifty - percent by the vo-
tech and fifty - percent from the county -wide 21 Century Community Learning Center Grant.
Bryan's salary was to be $60,000.00 per year (including benefits). Rembold, as WGSD
superintendent, participated in securing the countywide 21 st Century Community Learning
Center Grant. Effective September 19, 2001, Bryan's entire salary was funded by the
countywide 21 st Century Community Learning Center grant funds. Bryan was compensated
$56,146.14 by the vo -tech from the Greene County Educational Consortium, of which
Rembold is a member, with financing from a grant secured by Rembold.
Turning to the allegation concerning use of district facilities and materials, Rembold
submitted invoices to Kings Bridge at various times detailing days, amount of time, and rate of
compensation for conducting research, writing, and data collection relative to the PULSE
program. Rembold performed services for King's Bridge on the same dates he was listed as
working as WGSD superintendent. Leave records from WGSD for Rembold and invoices
submitted to King's Bridge by Rembold confirm dates he was performing work for King's
Bridge while simultaneously receiving compensation for working at the district. See, Fact
Finding 158. Rembold avers that the various dates represent days off for holidays, snow days
or leave days.
Rembold assisted Steven Wilcox, a King's Bridge associate, in presenting peer
counseling training for the Cabell County Board of Education at Camp Virgil Tate. Rembold
assisted Wilcox during the 1999 and 2001 training sessions on the following dates: Thursday,
March 4, 1998; Friday, March 9, 2001; and Friday, March 5, 1999. Rembold did not utilize
leave from WGSD on Thursday, March 4, 1999; Friday, March 5, 1999; or Friday, March 9,
2001. No leave was required by Rembold on March 4, 1998, which was a WGSD snow day.
March 5, 1999, was a vacation day as per the leave records. On March 9, 2001, Rembold
worked a full gay as Superintendent at WGSD and then traveled to Cabell County and worked
on March 10 and 11"', 2001.
Rembold has provided counseling /consultant services for the HASD since at least
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1996. Rembold was hired by the HASD PULSE coordinator Arthur Waleski, the assistant
high school principal. Waleski is also a compensated trainer for King's Bridge. Business
records of HASD reflect Rembold received compensation from that district during calendar
years 1996, 1997, 1998, and 1999. See, Fact Finding 174. Rembold served as a trainer for
a HASD PULSE retreat on April 7, 1999 through April 9, 1999. Rembold did not utilize leave
from WGSD on April 7, 1999, April 8, 1999, or April 9, 1999. Rembold was compensated by
HASD for conducting training for HASD while simultaneously receiving compensation from
WGSD. Rembold received $812.64 from WGSD while he was simultaneously paid by HASD
and did not utilize leave. This training did not relate to Rembold's duties as W GSD
superintendent.
WGSD has a policy governing the use of district equipment, including telephones and
fax machines. The board specifically prohibits, unless authorized, personal use of district
telephones, materials, tools, supplies, equipment, and district vehicles. This policy was in
effect throughout Rembold's tenure as WGSD superintendent. Employees of WGSD were
not permitted to use district phones /fax equipment to conduct personal business. Rembold
had access to general phone lines of the district while serving as Superintendent of WGSD in
that he did not have a direct phone line. Rembold made personal /personal business calls
using WGSD telephones. Some of the calls and faxes were directly related to King's Bridge
and /or PULSE activities. Rembold identified and made reimbursement to WGSD for making
personal /personal business calls and faxes for the period of July 2000 through March 2001.
Rembold made reimbursement on July 16, 2001, in the amount of $90.60. Rembold made
another reimbursement to the district for personal calls in the amount of $84.30 on September
18, 2001. Rembold made this reimbursement for the estimated amount of personal /personal
business calls made from district telephones for the period of April 2001 through June 2001.
For the period from December 1998 through December 2000, Rembold made
personal /personal business telephone calls from WGSD telephones in the total amount of
$97.33 for which he made no reimbursement. Long distance toll records for WGSD confirm
Rembold placing calls and faxes to PULSE and King's Bridge associates and other personal
calls /faxes on at least 271 occasions from May 1998 through December 2000. These calls
were made by Rembold to Edgar Thacker, Steve Wilcox and Arthur Waleski, and other
PULSE and King's Bridge Associates. These calls were separate from those Rembold had
made reimbursement payments to the district.
In addition to placing calls to PULSE and King's Bridge associates, Rembold received
calls at WGSD from Steve Wilcox, Edgar Thacker, Art Waleski, and Lonnie Woomer, all of
whom were connected to Rembold through PULSE and /or King's Bridge. Approximately 300
calls were placed by Wilcox to Rembold at WGSD from October 1998 through May 2000
totaling 1,670.3 minutes and $149.30. These calls were placed during the same time
Rembold was consulting with Wilcox on PULSE /King's Bridge business. Calls were placed to
Rembold at WGSD by Art Waleski from May 1995 through April 2001 at HASD totaling 266.9
minutes and $25.74. These calls were placed during the same time Rembold was consulting
with Waleski on PULSE. Calls were placed from May 1998 to August 29, 2001, totaling
822.07 minutes by Mainstream Counseling to WGSD while Rembold was employed as the
district superintendent. These calls were placed at a time when Mainstream Counseling had a
partnership agreement with King's Bridge and when Rembold was including Mainstream
Counseling on grant applications. Rembold also received and had faxes sent to Steve
Wilcox/SCSD regarding Rembold's involvement with PULSE and /or King's Bridge on several
occasions. Rembold's use of the telephone in relation to PULSE and /or King's Bridge related
activities while on WGSD time are delineated in Fact Finding 193. Rembold received a private
pecuniary gain of $2,080.95 as a result of transacting private business using WGSD's
telephone, during his work hours as superintendent.
In his capacity as WGSD Superintendent, Rembold received mileage reimbursement
for use of his vehicle while on official business. Expense reimbursement records on file with
WGSD confirm Rembold received mileage reimbursement for his attendance at PULSE
training held in Elizabethtown, Pennsylvania on days that he was on leave from the district.
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Rembold was not entitled to receive expense reimbursement from the district for expenses not
related to official WGSD duties. Rembold received mileage reimbursement on days when he
was not working for the school district. Rembold's expense records submitted to WGSD
included the mileage reimbursements for his attendance at PULSE trainings while on leave
from the district. Rembold received reimbursement from both WGSD and SCSD for travel
expenses related to Rembold's independent consultant activities. Rembold received duplicate
expense reimbursement for mileage from WGSD and the Greene County Industrial
Development Authority (GCIA), an entity on which Rembold serves as president, for expenses
related to authority business. Rembold submitted mileage reimbursement and received
payments for mileage unrelated to WGSD business which totaled $514.63. Rembold issued
checks to the WGSD as reimbursement for mileage as follows: $653.31 for all mileage
reimbursements made to him for travel to SCSD and $14.30 to WGSD.
Rembold, as WGSD superintendent, was annually required to file SFI's. Rembold
failed to file SFI's for calendar years 2000, 1999, 1998, and 1997 by May 1 of each following
year. Prior to late winter /early spring 2001, SFI's were only distributed to school board
members and the solicitor by the district business administrator. The business manager of the
WGSD did not circulate the forms to any administrator, including Rembold. No administrator in
the history of the WGSD ever completed SFI's until the spring of 2001 when the business
administrator learned that other personnel, including the superintendent, were required to file
SFI's. After consulting with the solicitor, the business administrator informed Rembold that he
and other administrators were required to file SFI's. Rembold did not file any SFI's with
WGSD prior to resigning in August 2001. Rembold completed SFI's for calendar years 2001,
2000, 1999, 1998, and 1997 on February 6, 2002, and filed them at WGSD on May 1, 2002.
Rembold eventually filed SFI's at the WGSD and disclosed the information listed in Fact
Finding 216.
Under Office, Directorship, Employment in any Business on his SFI's Rembold failed to
disclose A Community Agile Partners in Education for calendar years 1999 through 2001;
Green County Industrial Development Corp for calendar years 2000 and 2001; and
Evergreene Technology Park, Inc. for calendar year 2001.
Having highlighted the Stipulated Findings and issues before us, we shall now apply
the Ethics Act to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations.
The Consent Agreement proposes that this Commission find:
a. That Rembold violated Section 1103(a) of the Ethics Act when he used the authority of
his position as superintendent of the West Greene School District, to participate in the
school district's request for various grant funds to implement a program for at -risk
students, which grant fund requests identified, as one of the contractors to be utilized,
for the program, as King's Bridge Incorporated, at a time when he was officially listed
on corporate papers as one of the directors of that entity and when he had a
reasonable expectation that he would receive compensation from King's Bridge Inc. in
relation to the provision of services by Rembold relating to the At Risk Program, and
when he participated in the school district's selection of and payments to King's Bridge
Inc. to implement the program.
b. That a technical violation of Section 1103(9 of the Ethics Act occurred when the West
Greene School District selected King's Bridge Incorporated and contracted with that
entity to provide consultation services regarding the school district's implementation of
a program to deal with students at -risk, at a time when Rembold was officially listed on
corporate papers as one of the corporate directors when such selection and contract
was conducted without an open and public process.
c. That a violation of Section 1103(f) of the Ethics Act occurred regarding his continued
supervisory and overall responsibility for the implementation or administration of the
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contract between West Greene School District and Mainstream Counseling,
Incorporated at a time when Mainstream Counseling awarded a subcontract to King s
Bridge, Incorporated to participate in the PULSE Training at the West Greene School
District at a time when Rembold was formally listed on the corporate papers of King's
Bridge as a Director.
d. That an unintentional violation of Section 1103(a) of the Ethics Act occurred regarding
Rembold's receipt of compensation from the West Greene School District for one day
when he was also performing services for King's Bridge Incorporated on such days and
being compensated therefor.
e. That no violation of the Ethics Act occurred in relation to Rembold's receipt of
compensation from the West Greene School District on days that he was also
performing services for the Cabell County Board of Education, West Virginia, as the
days on which such activities occurred were not official school days in West Greene
School District.
f. That an unintentional violation of Section 1103(a) of the Ethics Act occurred in relation
to Rembold's performance of services for the Huntington Area School District, and the
receipt of compensation therefor, while simultaneously being employed and
compensated by the West Greene School District for the same days.
That no violation of the Ethics Act occurred in relation to Rembold's use of West
Greene School District facilities, equipment and personnel for the performance of
duties relating to his private employment with King's Bridge Incorporated, and the
Huntington Area School District, as such use was de minimis in nature.
h. That an unintentional violation of Section 1103(a) of the Ethics Act occurred in relation
to Rembold's receipt of compensation from the West Greene School District for time
spent while at the West Greene School District office facilities working on matters
relating to his work as an independent contractor for King's Bridge Incorporated and the
Huntington Area School District.
That no violation of the Ethics Act occurred in relation to Rembold's receipt of
expenses from both the West Greene School District and the Southern Columbia
School District for the same expenses relating to his outside employment endeavors,
as Rembold made reimbursement for the expenses for which he was
overcompensated, by West Greene School District.
That no violation Section 1103(a) of the Ethics Act occurred in relation to the hiring of
Rembold's son for a position of employment with the West Greene School District Vo-
Tech, as the decision to hire Rembold's son was made by the Joint Operating
Committee of the Vo -Tech.
g.
k. That a violation of Section 1103(a) of the Ethics Act occurred in relation to Rembold's
participation in the application for grant funds by West Greene School District which
funds were to be utilized in part for the payment of the salary of his son for work
performed at the West Greene Vo -Tech which had hired Rembold's son.
That Rembold unintentionally violated Section 1104(a) of the Ethics Act regarding his
failure to file Statements of Financial Interests for calendar years 1997 through 2000
inclusive, at a time when he served as superintendent for the West Greene School
District as no administrators at the school district were filing Statements of Financial
Interests.
m. Rembold agrees to make payment in the amount of $26,397.50 in settlement of this
matter, payable to the Commonwealth of Pennsylvania, Department of Treasury and
forwarded to the Pennsylvania State Ethics Commission. Said payment to be made no
Rembold 01- 079 -C2
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later than the 30 day after the issuance of the final adjudication in this matter.
Rembold, as the WGSD Superintendent, used the authority of his office to obtain
various grants, implement the students at -risk program, and participate as to contracts for
services with funds to King's Bridge, a business with which he was associated in his position
of director. Rembold, at a minimum, had a reasonable expectation that he would receive
pecuniary benefits from funds that would be received by King's Bridge. Rembold was the
linchpin of such financial scenarios. In his official capacity as superintendent, Rembold was
instrumental in bringing the PULSE Program to the school district, obtaining grant funds, and
orchestrating the usage of such grant funds for that program, resulting in compensation to
King's Bridge and himself. Such compensation was a private pecuniary benefit to King's
Bridge, a business with which Rembold was associated, and in particular to Rembold himself.
Rembold's actions met the conditions for a violation of Section 1103(a) of the Ethics Act.
There was no element of happenstance in this elaborate machination: Rembold
manipulated the system to ensure that after a series of events concluded, a portion of the
grant funds would be received by him. Despite Rembold's duty to act in the best interests of
the school district and most importantly, the students, he disregarded that duty and used
public office for personal financial gain in violation of both the letter and spirit of the Ethics Act.
In short, Rembold's course of conduct for his own financial ain was a flagrant abuse of the
public trust. Accordingly, Rembold violated Section 1103(a) of the Ethics Act when he, as
NGSD Superintendent, participated in school district's requests for various grant funds to
implement a program for at -risk students, which grant fund requests identified King's Bridge as
one of the contractors, when the corporate papers listed Rembold as one of the directors,
when he had a reasonable expectation that he would receive compensation from King's Bride
in relation to the provision of services, and when he participated in the school district's
selection of and payments to King's Bridge to implement the program. See, Shaner, Order
1163; Amato, Opinion 89 -002.
As to the contracting between WGSD and King's Bridge, the business with which
Rembold is associated, the Ethics Act provides for contracting between a public official or his
business and his governmental body but if the contract is $500 or more, it must be awarded
through an open and public process. See, Confidential Opinion, 97 -002. There was no
advertising for bids or disclosure as to such contracting in this case. Such is not surprising:
an open and public process would have invited competition, and competition would have
lessened Rembold's control over the process and his ability to steer work directly to King's
Bridge and indirectly to himself. Consistent with our prior precedent involving the contracting
provision of the Ethics Act, we find a technical violation of Section 1103(f) of the Ethics Act
when WGSD selected King's Bridge and contracted in excess of $500 without an open and
public process with that entity to provide consultation services regarding the school district's
implementation of a program to deal with students at -risk, when Rembold was officially listed
on corporate papers as one of the corporate directors. See, Whetstone, Order 1040; Shetler,
Order 951.
Although Section 1103(f) of the Ethics Act does not prohibit contracting between a
public official or his business and the governmental body, provided the requirements of the
Ethics Act are satisfied, the section prohibits the public official from having any supervisory or
overall responsibility regarding the administration or implementation of the contract. However,
in this case, that is precisely what Rembold did. Rembold exercised the administrative
implementation of the contract so that he would be the recipient of compensation as to the
provision of services under the contract. Rembold's actions as to the implementation and
administration of the contracting are prohibited by the Ethics Act. Accordingly, Rembold
violated Section 1103(f) of the Ethics Act as to his continued supervisory and overall
responsibility for the implementation or administration of the contract between WGSD and
Mainstream Counseling, Incorporated when Mainstream Counseling awarded a subcontract to
King's Bridge to participate in the PULSE Training at WGSD at the time Rembold was formally
listed on the corporate papers as a King's Bridge Director.
Rembold 01- 079 -C2
Page 59
As to the allegation of Rembold's receipt of compensation from WGSD while performing
services for King's Bridge, no analysis is necessary. Fact Finding 157 states: "Rembold
performed services for King's Bridge on the same dates he was listed as working as
superintendent for WGSD." The foregoing factually establishes that Rembold was receiving
compensation as a WGSD Superintendent while simultaneously providing services to King's
Bridge. In a multitude of prior precedent, we have consistently held that a public official /public
employee may not use government equipment, personnel, or facilities to conduct political, re-
election, or private business activities. See, Friend, Order 800; Heck, Order 1251;
Rockefeller, Order 1004; Cohen, Order 610 -R; Holt, Order 1153; Williams, Order 734 -R.
Hence, Rembold unintentionally violated Section 1103(a) of the Ethics Act when he received
compensation from WGSD for one day when he also performed services for King's Bridge.
There were other instances when Rembold was performing services for the Cabell
County Board of Education while WCSD Superintendent; however, in such cases, Rembold
either turned in a leave slip, WGSD closed due to weather conditions, or Rembold performed
the service after school district hours. In such circumstances, Rembold's outside activities did
not occur during official school hours. Hence, Rembold did not violate Section 1103(a) Ethics
Act when he received compensation from WGSD on days that he was also performing
services for the Cabell County Board of Education, West Virginia, as the days on which such
activities occurred were not official school days of WGSD.
There is another allegation concerning Rembold performing compensated services for
the HASD while the WGSD Superintendent. Fact Finding 177 provides in part: "Rembold
was compensated by HASD for conducting training for HASD while simultaneously receiving
compensation from WGSD." The specific details of Rembold's activities at HASD while he
was simultaneously listed as present at WGSD are detailed in Fact Findings 173 -177. Based
upon our analysis above and prior decisions on this issue, we find that Rembold
unintentionally violated Section 1103(a) of the Ethics Act when he performed services for
HASD and received compensation, while simultaneously being employed and compensated
by the WGSD for the same days.
These are similar type issues involving Rembold's use of school district facilities,
equipment, and personnel relative to his private business interests. The fact findings reflect
that Rembold used the school district facilities, equipment, and personnel in contravention of
the Ethics Act. However, the amount of quantifiable personal financial gain was limited and
small in amount. One of the two statutory exclusions to a conflict/ violation of Section 1103(a)
of the Ethics Act relates to a private pecuniary benefit where the economic consequence has
an insignificant effect. See, Schweinsburq, Order 900. On that basis, Rembold did not violate
Section 1103(a) of the Ethics Act when he used WGSD facilities, equipment and personnel
for the performance of duties relating to his private employment with King's Bridge and HASD
on a de minimis basis.
Another allegation is Rembold's use of school district facilities, equipment, and
personnel at WGSD while working on matters for King's Bridge and HASD. Based upon the
above precedent on this issue, a public official /public employee cannot receive compensation
for his public position when he is simultaneously performing business activities in a private
capacity. See, Holt; Williams, supra. Accordingly, Rembold unintentionally violated Section
1103(a) of the Ethics Act when he received compensation from the WGSD while working on
matters as an independent contractor for King's Bridge and HASD.
Turning to the issue of excessive expense reimbursements, there were uses of
authority of office by Rembold as the WGSD Superintendent. But for the fact that Rembold
was a superintendent he could not have submitted the duplicate expenses to both WGSD and
SCSD. Further, the excess expense reimbursements constituted private pecuniary benefits to
Rembold. Such definitive excess expenses were returned to the school district. Based upon
the foregoing, the Investigative Division, through the exercise of prosecutorial discretion, has
Rembold 01- 079 -C2
Page 60
determined that Rembold's actions did not constitute a violation of Section 1103(a). We will
treat the above as a non pros by the Investigative Division as part of a comprehensive
settlement in this case as to all of the allegations. Accordingly, Rembold did not violate
Section 1103(a) of the Ethics Act in relation to his receipt of expenses from both WGSD and
SCSD for the same expenses relating to his outside employment endeavors on the basis of a
non pros by the Investigative Division.
Regarding the allegation of the hiring of Rembold's son at the WGSD Vo -Tech, the
record reflects that Rembold used his position as WGSD Superintendent to request that his
son be hired by the Vo -Tech Joint Operating Committee. Although Rembold was not
employed by the Vo -Tech, he was the immediate supervisor of two of its members. Such
actions were uses of authority of office. A private pecuniary benefit resulted when Rembold's
son was hired to a compensated position. Rembold's son is a member of his immediate family
as that term is defined under the Ethics Act. However, this particular issue is not part of the
allegations in the case. Accordingly, Rembold did not violate Section 1103(a) of the Ethics
Act regarding his use of authority of office as to the hiring of his son to a compensated position
at the Green County Vo -Tech in that such is not part of the allegation in this case. See,
Pennsy v. Department of State, 594 A.2d 845 (1991).
As to the grant funding which was sought by Rembold and which was used in part for
the payment of the salary of Rembold's son, there were uses of authority of office by Rembold.
Rembold requested that his son be employed in the position with the Vo -Tech board, where
two of its members were subordinates of Rembold at WGSD. See, Fact Findings144, 147.
The uses of authority of office resulted in a private pecuniary benefit consisting of the partial
funding of the salary to Rembold's son, a member of Rembold's immediate family. Hence,
Rembold violated Section 1103(a) of the Ethics Act when he participated in the application for
grant funds by West Greene School District which funds were utilized in part for the payment
of the salary of his son for work performed at the West Greene Vo -Tech.
The final allegation concerns Rembold's failure to file SFI's for the 1997 -2000 calendar
years. The WGSD's business manager never circulated the SFI forms to the administrators in
the school district until the spring of 2001. Prior to that time, only the school board members
and the solicitor received the SFI forms. Rembold never received forms nor filed SFI's.
Rembold has now completed SFI's for the above years. Rembold failed to file because he did
not know that he was so required. However, ignorance of this law is no excuse. The Ethics
Act required Rembold to file SFI's but he failed to do so. We find that Rembold unintentionally
violated Section 1104(a) of the Ethics Act when he failed to file SFI's for calendar years 1997
through 2000, at a time when he served as superintendent for WGSD and no administrators
were filing SFIs.
We determine that the Consent Agreement submitted by the parties sets forth the
proper disposition for this case, based upon our review as reflected in the above analysis and
the totality of the facts and circumstances. Accordingly, Rembold is directed to make payment
in the amount of $26,397.50 to the Commonwealth of Pennsylvania, Department of Treasury
and forwarded to the Pennsylvania State Ethics Commission. Said payment to be made no
later than the 30 day after the issuance of the final adjudication in this matter. Compliance
with the foregoing will result in the closing of this case with no further action by this
Commission. Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. Rembold, as the Superintendent for the West Greene School District (WGSD), is a
public official subject to the provisions of Act 9 of 1989 as codified by Act 93 of 1998.
2. Rembold violated Section 1103(a) of the Ethics Act when he, as WGSD
Superintendent, participated in school district's requests for various grant funds to
implement a program for at -risk students, which grant fund requests identified King's
Rembold 01- 079 -C2
Page 61
Bridge as one of the contractors, when the corporate papers listed Rembold as one of
the directors, when he had a reasonable expectation that he would receive
compensation from King's Bridge in relation to the provision of services, and when he
participated in the school district's selection of and payments to King's Bridge to
implement the program.
3. Rembold technically violated Section 1103(f) of the Ethics Act when WGSD selected
King's Bridge and contracted in excess of $500 without an open and public process
with that entity to provide consultation services regarding the school district's
implementation of a program to deal with students at -risk, when Rembold was officially
listed on corporate papers as one of the corporate directors
4. Rembold violated Section 1103(f) of the Ethics Act as to his continued supervisory and
overall responsibility for the implementation or administration of the contract between
WGSD and Mainstream Counseling, Incorporated when Mainstream Counseling
awarded a subcontract to King's Bridge to participate in the PULSE Training at WGSD
at the time Rembold was formally listed on the corporate papers as a King's Bridge
Director.
5. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he received
compensation from WGSD for one day when he also performed services for King's
Bridge.
6. Rembold did not violate Section 1103(a) Ethics Act when he received compensation
from WGSD on days that he was also performing services for the Cabell County Board
of Education, West Virginia, as the days on which such activities occurred were not
official school days of WGSD.
7. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he performed
services for HASD and received compensation, while simultaneously being employed
and compensated by the WGSD for the same days.
8. Rembold did not violate Section 1103(a) of the Ethics Act when he used WGSD
facilities, equipment and personnel for the performance of duties relating to his private
employment with King's Bridge and HASD on a de minimis basis.
9. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he received
compensation from the WGSD while working on matters as an independent contractor
for King's Bridge and HASD.
10. Rembold did not violate Section 1103(a) of the Ethics Act in relation to his receipt of
expenses from both WGSD and SCSD for the same expenses relating to his outside
employment endeavors on the basis of a non pros by the Investigative Division.
11. Rembold did not violate Section 1103(a) of the Ethics Act regarding his use of authority
of office as to the hiring of his son to a compensated position at the Green County Vo-
Tech in that such is not part of the allegation in this case.
12. Rembold violated Section 1103(a) of the Ethics Act when he participated in the
application for grant funds by West Greene School District which funds were utilized in
part for the payment of the salary of his son for work performed at the West Greene
Vo -Tech.
13. Rembold unintentionally violated Section 1104(a) of the Ethics Act when he failed to
file SFI's for calendar years 1997 through 2000, at a time when he served as
superintendent for WGSD and no administrators were filing SFIs.
Rembold 01- 079 -C2
Page 62
In Re: Charles Rembold
ORDER NO. 1303
File Docket: 01- 079 -C2
Date Decided: 12/1/03
Date Mailed: 12/15/03
1. Rembold, as the Superintendent for the West Greene School District (WGSD),
violated Section 1103(a) of the Ethics Act when he, as WGSD Superintendent,
participated in school district's requests for various grant funds to implement a program
for at -risk students, which grant fund requests identified King's Bridge as one of the
contractors, when the corporate papers listed Rembold as one of the directors, when
he had a reasonable expectation that he would receive compensation from King's
Bridge in relation to the provision of services, and when he participated in the school
district's selection of and payments to King's Bridge to implement the program.
2. Rembold technically violated Section 1103(f) of the Ethics Act when WGSD selected
King's Bridge and contracted in excess of $500 without an open and public process
with that entity to provide consultation services regarding the school district's
implementation of a program to deal with students at -risk, when Rembold was officially
listed on corporate papers as one of the corporate directors
3. Rembold violated Section 1103(f) of the Ethics Act as to his continued supervisory and
overall responsibility for the implementation or administration of the contract between
WGSD and Mainstream Counseling, Incorporated when Mainstream Counseling
awarded a subcontract to King's Bridge to participate in the PULSE Training at WGSD
at the time Rembold was formally listed on the corporate papers as a King's Bridge
Director.
4. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he received
compensation from WGSD for one day when he also performed services for King's
Bridge.
5. Rembold did not violate Section 1103(a) of the Ethics Act when he received
compensation from WGSD on days that he was also performing services for the Cabell
County Board of Education, West Virginia, as the days on which such activities
occurred were not official school days of WGSD.
6. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he performed
services for HASD and received compensation, while simultaneously being employed
and compensated by the WGSD for the same days.
7. Rembold did not violate Section 1103(a) of the Ethics Act when he used WGSD
facilities, equipment and personnel for the performance of duties relating to his private
employment with King's Bridge and HASD on a de minimis basis.
8. Rembold unintentionally violated Section 1103(a) of the Ethics Act when he received
compensation from the WGSD while working on matters as an independent contractor
for King's Bridge and HASD.
9. Rembold did not violate Section 1103(a) of the Ethics Act in relation to his receipt of
expenses from both WGSD and SCSD for the same expenses relating to his outside
employment endeavors on the basis of a non pros by the Investigative Division.
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Page 64
10. Rembold did not violate Section 1103(a) of the Ethics Act regarding his use of authority
of office as to the hiring of his son to a compensated position at the Green County Vo-
Tech in that such is not part of the allegation in this case.
11. Rembold violated Section 1103(a) of the Ethics Act when he participated in the
application for grant funds by West Greene School District which funds were utilized in
part for the payment of the salary of his son for work performed at the West Greene
Vo -Tech.
12. Rembold unintentionally violated Section 1104(a) of the Ethics Act when he failed to
file SFI's for calendar years 1997 through 2000, at a time when he served as
superintendent for WGSD and no administrators were filing SFIs.
13. Per the Consent Agreement of the parties, Rembold is directed to make payment in the
amount of $26,397.50 to the Commonwealth of Pennsylvania, Department of Treasury
and forwarded to the Pennsylvania State Ethics Commission no later than the 30 day
after the issuance of the final adjudication in this matter.
a. Compliance with the foregoing will result in the closing of this case with no
further action by this Commission.
b. Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
Louis W. Fryman, Chair