In Scotch Plains-Fanwood Bd. of Educ. v. Educ. Ass'n, 139 N.J. 141, 152-53, 651 A.2d 1018 (1995), the Court addressed the definition of "discipline," stating: We construe that definition of "discipline" to reflect a legislative determination to distinguish the withholding of an increment for disciplinary reasons from an increment-withholding for reasons of teaching performance. Hence, we conclude that the statutory standard governing the withholding of increments based on teaching performance does not apply to the withholding of an increment as a means of discipline. However, N.J.S.A. 18A:29-14, and the case law interpreting that provision, remain applicable when "the reason for the increment withholding relates predominantly to the evaluation of a teacher's teaching performance." N.J.S.A. 34:13A-27d. 139 N.J. at 155, 651 A.2d 1018. The 1982 disciplinary amendment permitted the parties to submit disciplinary determinations to binding arbitration. However, the amendment provided that the procedure "agreed to by the parties may not replace or be inconsistent with any alternate statutory appeal procedure." Thus, because the withholding of a teacher's increment was appealable to the Commissioner of Education, N.J.S.A. 18A:29-14, the 1982 disciplinary amendment did not permit binding arbitration. Scotch Plains-Fanwood, supra, 139 N.J. at 154, 651 A.2d 1018.