| Government Type | Count | Relationship to Schools |
|---|---|---|
| School districts | 864 | Subject of this audit |
| Municipalities | 1,298 | Same geography; often share vendors, attorneys, brokers |
| Townships | 1,432 | Administer general assistance; sometimes share tax levy geography |
| Special districts | 3,227 | Park, fire, library, sanitary — same board member pool |
| Counties | 102 | Administer elections, SEI filings, tax assessments |
| TOTAL | 6,963 |
D230 (Consolidated HSD 230) operates in the same geographic area as Orland Park. D230's insurance broker relationship has not been publicly reviewed. The same broker — Horton Group, now Marsh McLennan Agency — almost certainly served both the Village of Orland Park and D230 simultaneously. One competitive RFP changed the Village's costs by $1M. D230 has 7,485 students and $22,481 per-pupil expenditures. What would a competitive RFP for D230's insurance save?
1. Board Member as Vendor Employee
A school board member whose employer is a vendor to the district has a statutory conflict of interest under 105 ILCS 5/10-9 and 50 ILCS 105/3 (Public Officer Prohibited Activities Act). The member must recuse from any vote involving their employer. Many districts have no systematic process for identifying these conflicts — they rely on self-disclosure.
How to find: FOIA each district for Statement of Economic Interests filings from all board members; cross-reference against vendor payment register
Red flag: board member recusal appearing in minutes — someone identified the conflict
2. Board Member Serving Multiple Governments
A person who serves on both a school board and another governmental body (park district, fire district, city council) may face conflicts when those bodies share vendors, contractors, or when one government takes action affecting the other. Mark Kelly at D230 — who serves on both D230 and feeder district D118 — is a documented example.
How to find: Illinois SOS election records; ILSBE candidate filings; cross-reference names across all board meeting minutes in a geographic area
Red flag: same person voting on the same vendor at two different governing bodies
3. The Same Broker/Attorney Serving Multiple Bodies in the Same Geography
When the same insurance broker serves both the school district and the municipality in the same city — as Horton served both Orland Park and D230 — the broker has an information advantage and a structural disincentive to offer competitive pricing to either. The municipality knows the school district's coverage. The school district knows the municipality's. The broker knows both. Neither government knows what the other is paying.
How to find: FOIA insurance broker identity from all governments in a geographic area; compare carriers, premiums, and coverage
Red flag: same broker, same carrier, significantly different premiums for comparable coverage between two governments in the same city
4. The Same Law Firm Advising Potentially Adverse Parties
A law firm that advises both a school district and a municipality in the same geography — on issues like boundary disputes, intergovernmental agreements, or shared service contracts — may have a duty of loyalty conflict under Illinois Rules of Professional Conduct 1.7. Most Illinois school district attorneys also advise other local governments. This is disclosed in their engagement letters —
How to find:
Red flag: same firm advises two governments that are parties to the same intergovernmental agreement
| Geography | Known Pattern | Investigation Target |
|---|---|---|
| SW Suburban (Cook/Will) | Horton Group served Orland Park + D230 | Compare insurance for all SW suburban govts; identify other Horton/Marsh clients |
| South Suburban (Cook) | Robbins Schwartz concentration; highest poverty districts | Board member employment cross-reference; vendor payment comparison |
| North Suburban (Lake/Cook) | High bond exposure; fast-growing EL population | Bond counsel conflicts; TBE compliance |
| Downstate Anomalies | Salt Fork, Pana, Paris-Union — FPS/debt flags | Life safety contractor identification; FPS fund audit trail |
| Statewide | The Sandner Group administers WCSIT + ISDA | Governing board members cross-reference against school districts |
The Local Government Cross-Reference database requires three data streams that will merge after the board minutes collection:
Board member names — from 10 years of board minutes (collecting in 20-25 hour session)
Employer identities — from Statement of Economic Interests filings at county clerks (5 ILCS 420/4A)
Other government boards — from Illinois SOS election records and ILSBE candidate filings
Vendor payments — from FOIA check register requests (pending) and Illinois Comptroller local government data
Insurance broker identity — from
Illinois Statewide School District Compliance and Equity Audit 2026 | auditor@illinoisschooldistrict.org | IllinoisSchoolDistrict.org