1
Active Conflict of Interest
Mark Rising / EAB vendor tie
1
Dual Role Flagged
Fosdick / Sen. Ellman staff
$420M
Referendum Construction
4 contractors identified
7
Board Members
All profiled below
$107.1M
Outstanding Bonds
Aa1 / AA rated
0
Vendors Cross-Referenced
ASA data captured — pending
New Findings — From District Scrape Data May 17 2026
Four Additional Flags Requiring Immediate Action
◆ Superintendent Departed May 2026 — Mid-Investigation
Dr. Adrian Talley departed May 2026 (farewell reception posted on district site). Board appointed Dr. John Price as incoming superintendent (announced December 12, 2025). A superintendent transition is when vendor relationships get restructured, contracts get renegotiated, and new arrangements are made. This is the highest-risk window for undisclosed conflicts. FOIA all contracts executed or renewed between January 2026 and the publication date. The board that approved the new superintendent hire — including Rising and Fosdick — needs to be cross-referenced against Dr. Price's prior district relationships.
◆ Six Executive Sessions in 60 Days — Nov–Dec 2025
The agent's scrape identified a cluster of six executive sessions between November 4–6 and December 2–4, 2025 — almost certainly surrounding the superintendent search that resulted in the Dr. Price appointment. Under 5 ILCS 120/2(c), each executive session must cite a specific statutory exception. Those citations must be listed in the public minutes. If they are not, that is an Open Meetings Act violation. FOIA the verbatim minutes and the recorded vote to close each session. If the OMA basis is not cited, file an OMA complaint with the Illinois Attorney General.
◆ ESSA Subgroup Failures — Actual Numbers from ISBE Data
Real numbers from the agent's ISBE data pull: EL math proficiency: 22.0% (below the 30% ESSA support floor). IEP math: 13.5%. Homeless math: 13.3%. Black math: 28.3%. Black chronic absenteeism: 29.6% (above 25% Title I focus threshold). Low-income chronic absenteeism: 28.5%. A Aa1/AA-rated district with $420M in approved construction spending and 84.9% EBF adequacy has these numbers. The board that approved the construction referendum — and the board that hired a new superintendent — needs to answer for each of these.
◆ TIF Districts Touching IPSD 204 Boundary — Not Yet Enumerated
Aurora and Naperville both have multiple active TIF districts. IPSD 204 spans both cities across DuPage and Will counties. The compliance matrix flags this as ORANGE: no one has yet enumerated which TIFs overlap the district footprint, what the annual increment loss is, or whether the district has ever formally objected or sought compensation through the Joint Review Board process. This is the same pattern that burned D135 and D230 in the Pekau territory — a district with $268K EAV per pupil that is still only at 84.9% EBF adequacy should be asking where the tax base went.
Primary Conflict of Interest
Mark Rising: EAB Sales Director + IASB Board + IPSD 204 Board Member
◆ The Structural Problem
Mark Rising simultaneously holds three positions that create an unresolved conflict of interest: (1) Sales Director at EAB — a K-12 consulting firm that sells advisory services directly to school districts; (2) member of the IASB Board of Directors, DuPage Division — the association that sponsors WCSIT and ISDA insurance pools through The Sandner Group; and (3) elected voting member of the Indian Prairie CCSD 204 Board of Education, where he votes on district contracts and expenditures.
1
EAB sells K-12 advisory services to school districts. Rising is EAB's Sales Director — his compensation depends on EAB winning district contracts. EAB's "How One District is Moving from Insight to Action with EAB" video appears on IPSD 204's BoardDocs, suggesting the district has engaged with EAB.
2
Rising sits on the IASB Board of Directors (DuPage Division). IASB sponsors WCSIT (Workers' Compensation Security Insurance Trust) and ISDA (Illinois School District Agency) insurance pools — administered by The Sandner Group. These pools represent $200-400M in annual no-bid expenditure across Illinois school districts. No competitive bid is required for WCSIT or ISDA enrollment under current law.
3
Rising votes as an IPSD 204 board member on district contracts, expenditures, and budget approvals. If IPSD 204 contracts with EAB for advisory services, Rising has a direct financial interest in that vote. If IPSD 204 participates in WCSIT or ISDA, Rising's IASB board seat creates a structural alignment between his policy role and the district's insurance spending.
4
Required disclosures: Illinois law requires board members to disclose conflicts of interest and recuse from votes where they have a financial interest. Whether Rising has disclosed his EAB employment and recused from any EAB-related votes is a public record question. FOIA requests targeting Rising's disclosures are listed below.
First FOIA Action: EAB Contract Status
The existence of an IPSD 204 engagement with EAB must be confirmed or ruled out. A board member selling advisory services to school districts cannot vote on or influence his own employer's contract with his own district. Request all EAB invoices, contracts, and board votes touching EAB as a vendor — and all of Rising's conflict-of-interest disclosures on file.
All 7 Board Members
Complete Board Relationship Network
💰
EAB sells advisory services to school districts. Rising's role is Sales Director — he is compensated based on EAB winning district engagements. IPSD 204 BoardDocs contains an EAB video ("How One District is Moving from Insight to Action with EAB") suggesting engagement.
🏫
IASB Board of Directors, DuPage Division. IASB is the sponsor of WCSIT and ISDA insurance pools, administered by The Sandner Group — $200-400M annual no-bid exposure. Rising's IASB seat connects him to the same insurance pool structure that exists at hundreds of Illinois districts.
⚖
Votes on IPSD 204 contracts and budget. Any EAB-related expenditure, any WCSIT/ISDA insurance vote, or any consulting contract Rising's employer could pursue creates a mandatory disclosure and recusal obligation under Illinois law.
◆ Primary Conflict
EAB Employer
IASB Board
Sandner/WCSIT Link
FOIA: EAB Contract
FOIA: Disclosures
🏠
Sen. Laura Ellman's 21st District covers western Naperville and portions of IPSD 204 territory. Fosdick is paid staff in that office — her employment depends on Ellman's political success and legislative agenda. Her school board role gives her proximity to district concerns that are directly relevant to her employer's legislative portfolio.
📄
IASB Legislative Delegate. Fosdick represents IPSD 204 at IASB and advocates for IASB's legislative positions — positions that are set by the same IASB board that includes Mark Rising. IASB's legislative advocacy directly affects Illinois school law, including provisions that protect the no-bid insurance pool structure.
🏫
North Central College adjunct faculty. NCC is a private college in Naperville. No direct conflict identified but the dual employment (state legislator staff + college adjunct + school board) creates compressed loyalties across three institutional interests.
◆ Dual Role
Sen. Ellman Staff
IASB Leg. Delegate
Structural Alignment
No Vendor Conflict Found
⚖
Attorney at Rolewick & Gutzke P.C. Wheaton-based firm. Primary practice area: estate and probate law. No identified school district legal work or conflict with IPSD 204's current counsel (Franczek). No direct vendor conflict identified.
🏆
IPEF (Indian Prairie Education Foundation) Director. IPEF is the district's nonprofit fundraising foundation. Karubas shares IPEF board membership with Catey Genc. IPEF handles donor funds that flow into district programming — the overlap between the IPEF board and the elected school board warrants scrutiny of how IPEF funds are allocated and who approves IPEF expenditures.
IPEF Director
Overlaps w/ Genc
No Direct Vendor Conflict
FOIA: IPEF Fund Allocation
⚖
SSA federal attorney. Federal civil service employment is insulated from state-level political pressure. No identified vendor conflicts. Prior DCFS and immigration law work provides social service background relevant to school district special populations.
🔍
No connections found to Claar, Morrison, Glotz, Gas N Wash/McEnery, Robbins Schwartz, EAB, WCSIT/Sandner, or known vendor networks as of May 2026 research.
✓ No Conflicts Found
Federal Employee
📋
Self-disclosed substitute teacher conflict in 2022. Donahue publicly disclosed and recused from votes related to substitute teacher pay, with compensation capped at $1,000. This is the correct procedure — the disclosure is on record. The transparency process worked in this instance.
🏛
Retired telecom executive. AT&T/Nokia background brings technology and contract management expertise. No identified conflicts with current IPSD 204 vendors or construction contractors as of May 2026 research.
✓ Disclosed 2022 Conflict
Recusal on Record
No Active Conflicts Found
🏫
Elgin Community College (ECC) institutional advancement. ECC is a feeder institution for IPSD 204 graduates entering community college. Demming's role involves fundraising and donor relations for ECC. No direct vendor conflict with IPSD 204 identified, but the school-to-college pipeline relationship is worth monitoring for any formal partnership or dual-enrollment arrangements where Demming could have influence on both sides.
🔍
No connections found to identified vendor networks, construction contractors, or political donor chains as of May 2026 research.
✓ No Conflicts Found
Monitor: ECC Partnership
🏆
IPEF Director — shares IPEF board seat with Justin Karubas. The overlap of two elected school board members also serving together on the IPEF nonprofit board creates a structural concentration. IPEF donor funds, grant approvals, and program spending decisions involve the same two people in two different capacities.
🔍
No vendor conflicts found. Stay-at-home parent/community volunteer profile. No identified employment conflicts, no connections to construction contractors, insurance pools, or political donor networks as of May 2026 research.
✓ No Vendor Conflicts
IPEF Overlap w/ Karubas
FOIA: IPEF Records
$420M Referendum Construction Program
Construction Contractors — No Cross-Reference Yet Completed
In 2024, IPSD 204 voters approved a $420 million construction referendum. Four contractors have been publicly identified as engaged on the program. None of these contractors has been cross-referenced against board member employer networks, political donation records, or the IASB/Sandner/WCSIT network.
| Contractor |
Role |
Location |
Project |
Status |
| Wight & Company |
Architect of Record |
Darien, IL |
Overall program architect |
◆ Not cross-referenced |
| Pepper Construction |
General Contractor |
Chicago, IL |
Waubonsie Valley HS |
◆ Not cross-referenced |
| Bulley & Andrews |
General Contractor |
Chicago, IL |
Neuqua Valley HS / Birkett ES |
◆ Not cross-referenced |
| Performance Services Inc. |
Specialty Contractor |
Lombard, IL |
LED lighting upgrades |
◆ Not cross-referenced |
Required Cross-Reference Actions
For each of the four contractors above: (1) Illinois Sunshine campaign finance search — donations to any IPSD 204 board member or their related PACs; (2) IASB/Sandner Group connection search; (3) IL SOS business entity search for related entities; (4) ARDC search for any attorney principals with school district legal work; (5) check whether any contractor has business relationships with EAB or with organizations connected to Mark Rising or Allison Fosdick's employer.
Academic Performance
ESSA Subgroup Performance Flags
Indian Prairie CCSD 204 serves approximately 26,000 students across DuPage and Will counties. Despite being a well-resourced district (Aa1/AA bond rating, $420M referendum approved), specific student subgroups are not meeting ESSA proficiency standards. A district with these financial resources should not have persistent subgroup gaps.
English Learners — Math
22.0% Proficient
Below 30% ESSA support floor → Targeted Support & Improvement required. EL ELA: 17.9%.
Students w/ IEPs — Math
13.5% Proficient
Critically below 30% floor. IEP ELA: 19.1%. Both trigger mandatory ESSA intervention plans.
Homeless Students — Math
13.3% Proficient
McKinney-Vento liaison not publicly named on district site (ORANGE compliance flag).
Black Students — Math
28.3% Proficient
Just below 30% floor. Black chronic absenteeism: 29.6% — above 25% Title I focus threshold.
Low-Income — Absenteeism
28.5% Chronically Absent
Above 25% ESSA threshold. Title I focus school designation triggered for affected buildings.
Overall District
ELA 71.6% · Math 63.0%
District-wide numbers look good. The subgroup gaps are buried beneath them. That is the point.
The Governance Connection
A board that is occupied with managing undisclosed conflicts of interest — vendor ties, dual employment roles, nonprofit overlaps — is a board that is not focused on closing subgroup achievement gaps. The $420M referendum was sold to voters as a tool for better outcomes. Voters deserve to know whether board members with vendor relationships influenced how those dollars are being spent, and whether those spending decisions are reaching the students who most need intervention.
Financial Profile
Bond Debt and Insurance — $107.1M Outstanding
$107.1M
Outstanding Bonds
MSRB EMMA registry
Aa1/AA
Bond Rating
Moody's / S&P
$420M
2024 Referendum
Voter-approved construction
84.9%
EBF Adequacy
Below 100% target — underfunded
Insurance Pools — WCSIT / ISDA Connection
If IPSD 204 participates in WCSIT (Workers' Compensation Security Insurance Trust) or ISDA (Illinois School District Agency) — both administered by The Sandner Group and sponsored by IASB — then Mark Rising's IASB Board of Directors seat creates a direct structural alignment between his governance role and the district's no-bid insurance expenditure. This is the same Sandner/WCSIT/ISDA structure that exists at hundreds of Illinois school districts with zero competitive bidding required under current law. FOIA the district's insurance carrier(s), premium amounts, and the date of enrollment in any IASB-affiliated pool.
Required FOIA Actions
15 FOIA Requests — Priority Order
Send to: FOIA Officer, Indian Prairie CCSD 204 · 780 Shoreline Dr, Aurora IL 60504
01
EAB (Education Advisory Board) contract: All contracts, invoices, purchase orders, and board votes related to EAB or any EAB subsidiary, FY2018–present. Include any memoranda of understanding, pilot agreements, or advisory service engagements.
02
Mark Rising conflict disclosures: All Statements of Economic Interest, recusal notices, and conflict-of-interest disclosures filed by Mark Rising, 2018–present. All minutes or vote records where Rising recused or disclosed a conflict.
03
Insurance carriers and pools: All insurance carriers for the district, FY2018–present. Specifically: workers' compensation carrier, general liability, property. Whether district is enrolled in WCSIT, ISDA, or any other IASB-affiliated pool. Annual premium amounts.
04
$420M construction RFP records: All requests for proposal, bid solicitations, bid responses received, and board vote records for Wight & Company, Pepper Construction, Bulley & Andrews, and Performance Services Inc.
05
Allison Fosdick conflict disclosures: All Statements of Economic Interest filed by Allison Fosdick, 2018–present. All minutes where Fosdick disclosed employment by Sen. Ellman's office or recused from any vote touching state legislative matters.
06
IPEF (Indian Prairie Education Foundation) grants: All IPEF grants awarded to district programs, FY2018–present. All IPEF board meeting minutes involving Karubas or Genc. Any contracts between IPEF and IPSD 204.
07
Legal counsel contract (Franczek): All executed fee agreements with Franczek, FY2015–present. All Franczek invoices, FY2020–present, with hourly rates, matter descriptions, and attorney names. Total annual legal spend.
08
Transportation contracts: All transportation service contracts, FY2015–present, including carrier name, per-mile or per-bus rates, route miles, and PTCRS submissions. Identify any special education transportation sub-contracts.
09
Annual Statement of Affairs FY2020–2023: Confirm district filed ASA with ISBE each year. Provide copies of all ASA filings. (Note: ISBE central database eliminated by HB2986 — this audit captured the data but district copies confirm completeness.)
10
Board member economic interest statements — all members: All Statements of Economic Interest filed by all seven current board members for the most recent three years. Cross-reference against employer records above.
11
Consulting contracts over $25,000: All consulting or professional services contracts over $25,000, FY2020–present, that were awarded without competitive bidding. Include basis for exemption claimed.
12
Rising recusal on construction votes: Specifically, all board votes on the $420M construction program — architect selection, contractor selection, change orders — and documentation of Rising's participation or recusal in each.
13
Donahue substitute teacher pay disclosures: Confirm 2022 self-disclosure is on record. All subsequent votes on substitute teacher compensation and Donahue's participation/recusal.
14
Bond disclosure documents: All MSRB EMMA official statements and continuing disclosure filings for outstanding bonds. Confirm disclosure of all material events, including board member conflicts.
15
ELL and special education intervention contracts: All contracts with outside providers for English Language Learner and special education services, FY2020–present. Cross-reference against ESSA subgroup performance data.
What Publishes Next
This Investigation Is Active
This page publishes the board member relationship network research as of May 2026. The vendor cross-reference — pulling IPSD 204's ASA data (captured before HB2986 eliminated the central database) and running every vendor payment against the identified networks — is in queue. The $420M construction contractor cross-reference against board member employer networks and campaign finance records is also pending. Both will be added to this page when complete.
Tips and documents: auditor@illinoisschooldistrictaudit.com · 866-312-6456
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