Who Needs Another Policy? Maybe You Do

By: Chris Vogel, CEBS​

It’s too bad board policies fall under the category of “blah, blah, blah” for some folks.

Like many attorneys who work with boards of trustees, Rachel R. Parisi, CEBS, must see a few stifled yawns when she mentions policies at a board meeting. As she writes in “What Is Your Fund’s Policy on Policies?” in the January 2015 Benefits Magazine, a lot of people have one of three reactions: (1) We already have policies in place, (2) nobody really looks at them or (3) they’re just boilerplate.

But policies don’t deserve the typical eye roll. Below, industry experts suggest a few policies benefit trust fund boards may need to consider.  ​

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Every trustee who has attended a Foundation educational program or read the late Joe Brislin’s definitive  Multiemployer Plans: A Guide for New Trustees knows that his or her board should have written policies on benefits, collections, investments, document retention, etc.

But the benefits world and technology move fast. Trustees whose funds aren’t keeping up with their policies may wind up in a quandary, looking for answers and guidance a policy would have provided. Or they may end up in trouble with the Department of Labor.

1. Trustee Education Policy
​Joseph J. Burke, CEBS, administrator of the Iron Workers’ Mid-America Funds, wrote in the November magazine’s Benefit Basics column that DOL auditors often ask about a fund’s trustee education policy. The education policy should provide clear guidance to trustees as to how they can enhance their knowledge. It can also provide institutional consistency from one generation of trustees to another.

​[Related: Sample Documents for Members: View policy examples shared by International Foundation members.]

2. Social Media Policy
Attorney Andrew E. Staab gave tips for creating a social media policy in the May 2014 Benefits Magazine, and a sample policy from the Iron Workers of Western Pennsylvania Benefit Plans accompanied the article. As social media use continues to grow both in and out of the workplace, so does the need for a policy that protects confidentiality and lays out clear expectations.

3. Cyber Policy
Parisi suggests that technology may be necessitating another policy trustees might not have thought of–a cyber policy with provisions on passwords, remote access, workstations and security, disposal methods, removable media and incident reporting. She also suggests, and gives good reasons why a fund might need, policies on disaster recovery, how to deal with a HIPAA breach, employer withdrawal liability, expense sharing and reviewing service providers.The intial reaction to “We need a policy for that” may be to run and hide. But well-written policies can protect and provide clarity. You’ll often be glad you had them. And remember, policies need to be taken off the shelf every once in a while and dusted off to be sure they’re kept up to date, as well as complied with.

The intial reaction to “We need a policy for that” may be to run and hide. But well-written policies can protect and provide clarity. You’ll often be glad you had them. And remember, policies need to be taken off the shelf every once in a while and dusted off to be sure they’re kept up to date, as well as complied with. ​

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