PART 1: Invisible Bonds: How Two County Superintendents Exercise Cross-County Authority Over 64 Independent Agencies Through the Inland Personnel Council (IPC)

Are school districts beholden to a decades-old, auto-renewing Joint Powers Agreement that states they are “bound by” an ever-evolving contract they’ve never signed?

This is Part 1 of an ongoing series examining the structure and operations of the Inland Personnel Council (IPC). (Please note that this is a constantly changing story as new documentation is provided and included in the post. Please check back for updated information.)

The Inland Personnel Council (IPC) operates across dozens of public agencies, multiple contracts, and two counties—but the agreements that define how it actually functions are not clearly presented to governing boards or the public.

What is often described as a simple Joint Powers Agreement is, in practice, a layered contractual structure that determines how districts receive legal services and how those services are directed across agencies.

At its core, the issue is not whether districts chose to participate at some point in time, but whether current governing boards understand the agreements that continue to bind them—and the authority those agreements place in the hands of two county superintendents.

What IPC Is — and What It Appears to Be in Practice

The Joint Powers Agreement defines IPC as a “group of school districts,” suggesting a limited cooperative arrangement among independent agencies.

According to the IPC website, the Inland Personnel Council has existed since approximately 1980. Over time, it has evolved into a cross-county structure in which two county superintendents direct legal services across dozens of independently governed agencies.

That structure—and the contracts that support it—are where the real questions begin.

This article examines three interconnected issues: the two-part IPC contractual structure, the separate district agreements with the law firm Atkinson, Andelson, Loya, Ruud & Romo (AALRR) that may be contributing to confusion, and the lack of transparency surrounding how these systems operate.

LAYER ONE: THE JOINT POWERS AGREEMENT BETWEEN DISTRICTS

The Joint Powers Agreement defines the Inland Personnel Council (IPC), or “the Council,” not as a separate entity, but as “the school districts, as a group,” which also includes the San Bernardino County Superintendent of Schools (SBCSS) and the Riverside County Office of Education (RCOE) as participants.

In other words, IPC is not established as an independent organization—it is simply the collective name for the participating districts.

Yet in practice, IPC appears to function as something more. IPC issues invoices, is listed as a vendor in district accounting records, receives funds, coordinates services, and is described as employing a Director. Those are functions typically associated with an entity.

That disconnect raises a fundamental question: if IPC is only a “group of school districts,” what is the legal basis for it operating as if it were one?

The stated purpose of the Council reflects a more traditional cooperative model:

“The purpose of the COUNCIL shall be to seek and share expert legal services and advice on matters relating to personnel and employer-employee relations, to communicate among the member districts in seeking solutions to such problems, and to study and review the problems unique to employer-employee relations.”

However, the structure of the agreement itself raises additional questions.

The Joint Powers Agreement states that it is entered into by the school districts “designated below.” Yet no other districts are identified in the document. There is no clear mechanism for identifying all participating agencies, nor any provision requiring notification when agencies join or withdraw. As a result, a district may enter into—or remain part of—an agreement without knowing all of the other parties involved.

The only known record of IPC District Members appears on the IPC website, where the membership includes all 64 school districts, college districts, Regional Occupation Programs (ROPs) in the two counties. This membership list has remained completely static for over a decade according to internet archives.

In many cases, governing boards last approved this Joint Powers Agreement decades ago. Because the agreement includes an unusual automatic renewal clause, it continues in effect year after year without being brought back to current boards for review, discussion, or approval in open session.

This means current boards may be bound by an agreement they did not vote on, may not have reviewed, and may not even realize is still in effect—even as membership dues continue to be paid, often on a semi-annual basis, and potentially without clear board awareness.

See the sample Joint Powers Agreement below.

Missing Bylaws: The Critical Operational Component Cannot Be Found

The Joint Powers Agreement does not operate on its own. It explicitly contemplates the existence of bylaws that govern how the Council functions.

Those bylaws are not a minor administrative detail—they are the rules that define how the structure actually operates. They would be expected to address fundamental issues such as how decisions are made, how the Advisory Committee functions, how members are appointed or removed, how meetings are conducted, how funds are managed, and how authority is exercised within the Council. They would also be expected to be attached to the Joint Powers Agreement as a critical component of the contract.

Yet, the bylaws do not accompany the Joint Powers Agreements, and there are no public record of the bylaws that has been discovered via public records and extensive searches of online board agendas.

That absence is critical.

Without the bylaws, governing boards do not have access to the rules that define how the structure actually operates. Those rules would establish how services are directed by the County Superintendents in their roles as Executive Officers, how decisions are made—including how funds are controlled and allocated—how Advisory Committee members are selected and how that Committee influences those decisions, and how authority is delegated within the structure, including who is empowered to act on behalf of participating districts and under what limits.

Without access to these governing rules, boards cannot fully understand who is making decisions, how those decisions are made, or the extent of the authority they may have already ceded.

In practical terms, districts appear to be participating in a structure without having access to the governing framework that explains how that structure functions.

This raises a fundamental problem of oversight and public transparency. Governing boards cannot meaningfully evaluate, approve, or continue participation in an agreement when the operational rules that give that agreement effect have not been provided.

It also raises a threshold legal question: if the bylaws are referenced as part of the structure but have not been produced, can districts be said to have knowingly agreed to the full terms of participation?

At a minimum, the absence of bylaws prevents informed decision-making.

More fundamentally, it raises the question of whether districts can or should continue to participate in a structure whose governing rules have not been made available for review.

Districts “Bound By” an Unseen and Ever-Changing Contract

The Joint Powers Agreement does more than establish participation—it incorporates a second contract executed only by the County Superintendents and Atkinson, Andelson, Loya, Ruud & Romo (AALRR), without any clear evidence that participating districts have reviewed—or even seen—this critical operational component of the structure.

It provides that the Executive Officers “shall execute an Agreement for Special Services… on behalf of COUNCIL members,” and that this agreement may be amended annually. It further requires that “continuing COUNCIL members agree to comply with and be bound by the provisions of the Agreement for Special Services then in effect.”

That language is critical - and disturbing.

It means districts are agreeing in advance to be bound by a separate contract they do not sign, may not have seen, and that can be continually changed over time without direct knowledge or approval by their governing boards - or the public.

In practical terms, the structure allows the core terms governing services, fees, and obligations to be continually modified by the County Superintendents and a private law firm in a separate contract, with those changes automatically binding districts regardless of whether those districts review or approve them.

This is not a static agreement—it is an evolving one, with terms that can change while participation remains automatic, limiting transparency into the actual terms governing the Joint Powers Agreement.

These changes to one contract lead to inconsistencies between the agreements and further complicate the structure. For example, the Joint Powers Agreement specifies that participation is limited to “school districts.” Yet the IPC website now includes additional entities such as community college districts and Regional Occupational Programs (ROPs), without corresponding changes to the original Joint Powers Agreement signed by the school districts.

This creates the potential for conflicting or inconsistent terms between the Joint Powers Agreement and the county-level Agreement for Special Services.

Authority Shifted to County Superintendents

The Joint Powers Agreement grants substantial authority to the County Superintendents—Ted Alejandre of San Bernardino County and Edwin Gomez of Riverside.

Under the agreement, they are authorized to determine membership dues, create bylaws governing operations, select legal counsel, appoint and participate in the Advisory Committee, and direct services across all participating agencies. The agreement also authorizes the transfer of funds from district accounts.

County superintendents do have statutory responsibilities under Education Code section 1240, but those duties are limited. They do not serve as the governing boards of independent school districts, and nothing in section 1240 appears to authorize two county superintendents to jointly dictate services, fees, and contractual terms for dozens of separate agencies across county lines.

This creates a clear tension between the authority exercised under the IPC structure and the statutory limits placed on county superintendents under California law.

Withdrawal: Limited Ability to Exit the Agreement

If districts are bound to evolving terms—and those terms are unknown and controlled at the county level—the ability to exit the agreement becomes critical.

However, withdrawal from the IPC Joint Powers Agreement is not automatic.

It requires formal board action and written notice to both County Superintendents—one of whom may be outside the district’s own county—by a specific deadline each year.

In effect, a locally elected governing board must request withdrawal from officials of county agencies that do not govern that district.

This raises a fundamental question: what authority do the County Superintendents have to allow or restrict an independently elected school board from deciding that the IPC agreement is no longer in the best interest of its local constituents?

2011 IPC Joint Powers Agreement with Baldy View ROP.pdf

Download PDF • 140KB

LAYER TWO: THE AGREEMENT FOR SPECIAL SERVICES

This agreement is executed by the County Superintendents and the law firm Atkinson, Andelson, Loya, Ruud & Romo (AALRR)—the service provider selected by the County Superintendents—but not by the districts themselves.

Under the Joint Powers Agreement, districts have granted authority to the County Superintendents, who in turn execute this agreement on their behalf. Through that structure, the County Superintendents—and the vendor they have selected—are authorized to define and amend the terms governing services provided to participating districts.

It defines the services provided, membership pricing, and the overall structure of the program. Critically, it allows AALRR, as a vendor and party to the agreement, to participate in amending those terms on an annual basis.

That point is not theoretical—it is how the agreement has actually evolved.

Because districts are already required, under the Joint Powers Agreement, to “comply with and be bound by” whatever version of this agreement is in effect, changes made at the county level—including those shaped or amended by the vendor—become binding on districts without their signatures, without board approval, and without board awareness.

In practical terms, a vendor is able to participate in changing the terms of an agreement that districts are required to follow.

This raises serious concerns regarding fiduciary responsibility. Governing boards are tasked under the Education Code with oversight of public expenditures, yet taxpayer funds may be committed to evolving services and costs that are not clearly presented to the board. If the terms themselves can change without review, the ability to exercise meaningful oversight is called into question.

Termination and the Practical Limits on Exit

The structure of the Agreement for Special Services also raises concerns regarding termination of the Joint Powers Agreement.

The county-level contract provides that termination requires collective action by a majority of participating agencies across both counties, creating a significant practical barrier to exit.

There is no clear mechanism for school districts, community college districts, and Regional Occupational Programs (ROPs) to jointly deliberate or vote on continuation or termination of the agreement across two counties.

In practical terms, the structure risks becoming self-perpetuating, with no clear or workable path for dissolution of this publicly-funded agreement.

The 2020 Addendum — When Amendment Authority Was Used

The ability to amend the agreement is not simply a clause—it has been exercised-without clear notice to districts.

In 2020, the Agreement for Special Services was significantly expanded through a four-page addendum, effectively doubling the length of the original contract. This addendum was executed at the county level and signed only by the County Superintendents and AALRR.

This was not a minor clarification or administrative update. It was a substantial expansion of both services and authority.

The addendum introduced new categories of services, expanded the role of AALRR, and increased the scope of the firm’s involvement across participating districts. It added provisions requiring arbitration of disputes, expanded billing practices, and introduced additional fees and cost structures that were not present in earlier versions.

One of the most consequential changes was the integration of investigative and post-investigative roles. Under the addendum, an attorney who conducts or is involved in an investigation may later be required to prepare for, testify in, or otherwise participate in litigation, arbitration, or related proceedings arising from that same matter.

That shift is significant. It moves the structure beyond a traditional advisory or training model into a system where the same firm may be involved at multiple stages of a matter—training, initial complaint review, investigation, post-investigation services, and litigation—potentially across multiple entities.

The addendum also includes joint representation provisions, allowing AALRR to represent multiple parties within the same matter under certain conditions. It further expands consulting and advisory services into areas that may overlap with internal district functions.

In addition, the addendum modifies the financial structure of the agreement. It allows for expanded billing practices, including consulting-related charges and percentage-based fees, and introduces financial terms that directly affect how costs are allocated across participating districts.

All of these changes were implemented without direct approval or signatures from the district governing boards, yet according to the Joint Powers Agreement, the districts must "comply with" and are "bound by" these terms - even if unknown.

This agreement also introduces a pricing structure tied to legal services, including discounted hourly rates offered through separate AALRR contracts and conditioned on IPC membership—an element that does not appear in the original Joint Powers Agreement.

This has created significant confusion between IPC’s role as a training and coordination structure and AALRR’s role as a provider of legal services. The discount is not part of IPC itself; rather, it is a pricing feature within AALRR’s separate legal services contracts, available only if a district chooses to use AALRR and maintains IPC membership.

This distinction is not clearly reflected in public-facing materials. For example, the IPC website states that IPC “provides member districts with legal services… [including] legal support for the areas of facilities, student services and special education.” However, those “adjunct services” are not provided by IPC as a Joint Powers Agreement. They are legal services performed and billed by AALRR under separate contracts.

The fact that the IPC website is created and maintained by AALRR, and includes descriptions that attribute legal services to IPC rather than to the law firm providing them, raises concerns about transparency and whether the structure is being clearly and accurately presented to participating districts and the public.

A Fundamental Question of Authority

Taken together, these provisions reflect a significant - and potentially troubling - departure from the original framework approved by districts under the Joint Powers Agreement.

Under the IPC structure, the law firm Atkinson, Andelson, Loya, Ruud & Romo (AALRR)—acting as a vendor—can amend the contract while districts remain obligated to “comply with and be bound by” the current version. In effect, AALRR has drafted and revised contract terms—including through the 2020 and 2023 addenda—that expand its scope of services, provide protections for itself, and dictate how public funds are spent on those services, directly benefiting the law firm.

This raises serious concerns about authority and conflict of interest, particularly where independent governing boards did not review or approve those changes.

Whether those provisions are enforceable under California law remains an open question.

2023-2026 IPC County level contract with addendum.pdf

Download PDF • 452KB

OPTIONAL OVERLAY: DIRECT AALRR CONTRACTS AND THE MISSING COST-BENEFIT ANALYSIS

The “discounted rate” structure is not incidental—it is the mechanism that links IPC membership to AALRR legal services.

District-level contracts frequently condition discounted legal rates on IPC membership, creating a financial incentive for districts to remain within the IPC structure. While IPC is presented as a collaborative arrangement for training and coordination, this pricing linkage effectively connects it to the law firm’s separate legal services contracts.

Separate from IPC, many districts also enter into direct legal services contracts with Atkinson, Andelson, Loya, Ruud & Romo (AALRR). These contracts exist outside the Joint Powers Agreement, but overlap with IPC in ways that create significant confusion about how the system operates.

In many cases, these district-level contracts tie billing rates directly to IPC membership. For example, some agreements provide that legal services will be billed at discounted rates only “during any period in which the District is a member in good standing of the Inland Personnel Council.”

This creates a direct financial link between IPC participation and access to discounted legal services from AALRR—even though IPC itself does not provide those services and the contracts are legally separate.

In practical terms, IPC has shifted away from a collaborative training structure originally contemplated by the Joint Powers Agreement to a system that links IPC membership to discounted legal services from a specific vendor - AALRR.

In practice, this overlap has led to widespread confusion. Some districts believe they are receiving discounted services through IPC while simultaneously asserting they are not members. Others appear to believe that access to AALRR services at favorable rates requires IPC participation. Public records reflect uncertainty among districts about whether they are members, whether they are paying dues, and how those payments relate to the services they receive.

This single board document from Temecula Valley Unified School District (below) reflects this confusion in a series of fundamental inconsistencies in how the Inland Personnel Council (IPC) is described. It first presents IPC as providing “member discounts with legal services, advice and professional development,” framing it as a discount program. It then states that “the Inland Personnel Council has increased their hourly billing rate for direct legal and representational services,” attributing legal billing rates to IPC. Finally, it identifies membership fees as “payable to the Inland Personnel Council,” treating IPC as if it were a standalone entity capable of receiving funds.

These descriptions cannot all be true. Under its Joint Powers Agreement, IPC is defined only as a “group of school districts,” funded through membership dues set by its Executive Officers—not a law firm, not a billing entity, and not clearly established as a separate legal entity. Legal services are performed and billed by the law firm Atkinson, Andelson, Loya, Ruud & Romo (AALRR), either through the IPC structure or through separate contracts. Presenting IPC as a discount provider, a source of hourly billing rates, and a payee in the same document blurs these distinctions and creates confusion about who is providing services, who is setting hourly rates for AALRR direct legal services, and where public funds are actually going.

No Clear Cost-Benefit Analysis of Public Funds

Despite these overlapping agreements, there appears to be little evidence that governing boards—or the public—have been presented with a clear cost-benefit analysis.

At a minimum, such an analysis would compare:

• the cost of IPC membership

• the actual dollar value of any legal “discounts”

• the cost of attending IPC trainings and conferences as members versus non-members

• and the cost of obtaining comparable services from other law firms

Public records also show that IPC conferences are held at resort and spa locations, with hotel rates of approximately $350 per night, and agendas that include “Attorney Time - Cocktail Hour”—all funded with public dollars.

These two records below raise significant concerns about transparency, financial control, and basic fiscal oversight. The email instructs attendees not to book hotel accommodations directly, requiring all reservations to go through IPC, while the purchase order shows the district paying “Inland Personnel Council”—with an AALRR email contact—rather than the hotel itself.

This structure is atypical and obscures who is actually receiving and processing public funds for lodging, while also conflicting with representations that IPC is not a formal entity and maintains no financial accounts. Compounding these concerns, the Redlands Unified School District purchase order is dated February 2026 for a conference held in October 2025, indicating after-the-fact authorization of an already-incurred expense.

Together, the mandatory booking requirement, indirect payment structure, and delayed approval raise questions about undisclosed markups or bundled pricing, lack of pre-approval controls, and whether governing boards had any meaningful visibility into or authorization over how public funds were being spent.

Are these costs being factored into any meaningful cost/benefit analysis, and do these expenditures truly result in a “public benefit” justifying the use of taxpayer funds?

Without a clear accounting of how these expenses are structured, billed, and ultimately paid—including lodging routed through IPC rather than directly to vendors—it is difficult to determine whether IPC participation yields measurable savings or simply redistributes costs within a system that lacks transparency and effective oversight.

A Structural Conflict in Evaluating the System

Compounding the issue, the same firm that participates in and benefits from this structure often serves as legal counsel to the districts attempting to understand it.

As a result, governing boards seeking guidance on whether IPC participation is necessary, lawful, or financially beneficial may be relying on the very firm embedded within that structure to provide that analysis.

This raises a fundamental question:

How can governing boards make informed decisions about public expenditures when the agreements determining those costs are layered, interdependent, and not clearly presented for independent review?

AALRR also advises and coordinates district responses to public records requests, raising additional concerns about whether the same firm involved in structuring and delivering these services may also be influencing the flow of information to the public regarding its own role, services, and operations.

CONCERNS ABOUT IPC’S LACK OF TRANSPARENCY AND FAILURES OF OVERSIGHT

IPC Director and Conflicts of Interest

The IPC website states that IPC employs a part-time Director, identified as Jeff Malan.

That raises a basic question: if IPC is defined in its Joint Powers Agreement as a “group of school districts,” how does that “group” employ a Director? Employment requires an entity with authority to hire, supervise, and compensate, along with oversight and accountability from a governing body.

Here, those elements are not clear. There is no readily identifiable public record showing which governing board authorized the position, how the Director was selected, who supervises the role, or how it is funded. If IPC is not a separate entity, those questions become more significant.

Additional concerns arise from overlapping roles. Mr. Malan was recently appointed to the Board of Directors of the Barstow Community Foundation, which raises funds for Barstow Community College—an IPC member. Malan's Foundation biography does not disclose his current role as IPC Director, a position he has held since 2023.

These overlapping roles raise questions about transparency, disclosure, and potential conflicts of interest. More broadly, they highlight a recurring issue within the IPC structure: roles, authority, and relationships are not clearly defined or publicly documented, making it difficult for governing boards—and the public—to understand who is making decisions, under what authority, and in whose interest.

Absence from County Oversight Records

Despite the scope of IPC’s activities and its cross-county structure, there appears to be little to no record of IPC in publicly available county-level oversight materials.

County Boards of Education—responsible for oversight of county offices, budgets, and major contracts—do not appear to have discussed IPC in board meetings, nor is IPC clearly identified in publicly available audit reports.

This absence is notable. If IPC involves the coordination of services, expenditures of public funds, and contractual relationships affecting dozens of agencies, it would reasonably be expected to appear in board agendas, meeting discussions, or financial audits at the county level.

Its apparent absence from those records raises additional concerns about transparency and oversight, and whether governing bodies at both the district and county level have been provided a complete picture of the structure and its financial and operational impact.

Public records also indicate that the Riverside County Office of Education retained outside legal counsel—a law firm based in Fresno—to respond to Public Records Act requests related to IPC. Why is outside legal counsel needed to provide basic public records when the County Superintendent is directly involved as an IPC Executive Officer, member, and Advisory Committee participant?

Calls for DA Investigations, SANDABS, and the March SBC Sentinel Exposé

Over the past several months, concerns about IPC have moved into the public sphere.

In December, a request for investigation was submitted by a member of the public to the District Attorneys for Riverside and San Bernardino Counties, raising concerns about potential Brown Act violations due to the lack of publicly posted agendas and meeting minutes for IPC Advisory Committee meetings.

Public comments at school board and county board meetings followed, along with social media discussions and a long-form podcast questioning the lack of transparency, absence of public oversight, and unclear governance structure.

These concerns have expanded beyond local meetings. Requests for review have now been made to both District Attorneys and the California Attorney General.

The issue is not without precedent. The California Attorney General, Rob Bonta, previously examined a similar structure known as SANDABS and found it violated the Brown Act due to a lack of transparency and failure to conduct public business openly. That structure also involved Ted Alejandre, who now serves as an Executive Officer of IPC.

Public awareness increased significantly in March, when the San Bernardino County Sentinel published its investigative report, “Shadow Government in San Bernardino County & Riverside County Schools.”  The article brought attention to IPC as a decades-long, cross-county structure affecting dozens of agencies without the transparency typically expected of public governance.

Since then, additional Brown Act complaints have been filed, including Cure and Correct demands that have gone unanswered within the required 30-day timeframe by multiple school districts, which have never brought forth discussions of IPC to the public.

Across these developments, questions continue to emerge: how is IPC structured, who is actually in control, and why are districts not being transparent?

Upcoming IPC Advisory Committee Meeting – Public Attendance

Public records posted on social media also reveal an internal email exchange between IPC Director Jeff Malan and Advisory Committee member Danny Polmounter of Hesperia Unified School District regarding the next Advisory Committee meeting.

According to that communication, the meeting is scheduled for April 22 at 1:00 p.m. at The State restaurant in Riverside. The exchange reflects Mr. Malan’s role in coordinating the Advisory Committee, underscoring his central involvement in organizing and directing IPC activities.

At the same time, the meeting appears to be taking place outside of public view. Members of the public have requested the agenda for this meeting, expressing their intent to attend and make public comment to the Advisory Committee regarding their concerns about IPC.

To date, no agenda has been publicly posted on the IPC website.

While internal communications show that Advisory Committee meetings are being actively scheduled and coordinated, there is no corresponding public-facing process that would allow for transparency, public participation, or oversight.

Board Responsibility and Oversight of Contracts, Finances, and Staff

School boards have a fiduciary duty to taxpayers and are responsible for how public money is spent. That includes approving contracts and understanding exactly what they are paying for.

The lack of awareness and understanding of the contractual arrangements with the Inland Personnel Council (IPC) raises serious concerns about whether that oversight is actually occurring—or whether governing boards have ceded that responsibility to county superintendents, district staff, and even vendors who are influencing where public funds go.

Elected officials represent the public—not employees or vendors—and are entrusted to use public funds wisely and respectfully. Public records showing employees staying at high-end resorts at approximately $350 per night for IPC conferences which include “Attorney Time and Cocktail Hour.” These expenditures deserve closer scrutiny by board members as they may constitute inappropriate expenses and the potential misuse of taxpayer funds.

School board members cannot claim complete ignorance. IPC membership dues are paid every six months, and IPC is often established as a vendor in district accounting systems, indicating that district staff are aware of these recurring expenditures. If that information has not been clearly communicated to governing boards, it reflects a breakdown in communication—and a failure of board oversight of its employees.

The story of IPC should serve as a wake-up call for governing boards. It raises serious questions about other contracts that may be in effect with potentially unknown ramifications, and other public funds being spent without proper oversight. To restore the public trust, board members need to exercise their oversight authority as elected officials representing members of the public and their hard earned tax dollars.

Questions Boards and Administrators Should Be Asking

Boards must ensure they fully understand the IPC Joint Powers Agreement and the county-level Agreement for Special Services—specifically, whether the transfer of authority to county superintendents exceeds the board’s authority, whether those provisions are enforceable, and whether the arrangement is truly beneficial to their districts and the constituents who ultimately bear the cost.

What are we actually part of? Where are the bylaws, who are the members, and when did this board last review or approve the agreement?

What are we legally bound to? How are districts required to follow a separate services agreement they did not sign—and that can be changed without their approval?

Who controls the terms, decisions, and termination? What authority allows county superintendents to set services, fees, and structure across independent districts—and to influence whether and how districts can exit the agreement?

What are we paying—and where is it recorded? Are IPC costs embedded in legal services billing, and how are those expenditures tracked and approved?

Are we actually saving money? Do any “discounts” outweigh the full cost of participation, including conferences, travel, and related expenses?

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COMING NEXT: PART 2

Part 2 will examine how this structure operates in practice—particularly in investigations involving employees, students, and other matters, including sexual harassment and Title IX issues in the wake of AB 218—and how the 2020 addendum expanded the role of legal counsel. It will also look at the IPC online portal and the handling of sensitive personnel data across agencies, the impact on students, employees, and community members, and the cost to taxpayers through litigation and settlements, as well as potential conflicts of interest within the structure.