Wcribma - Veba

“Under the terms of the wcribma-veba trust agreement, the governing committee of the wcribma (governing committee) serves in the capacity of the organization's governing body.”

“The "members" of the organization are the companies licensed to write workers' compensation insurance in massachusetts, who are also members of the wcribma. The wcribma is a tax-exempt entity under irc sections 501(c)(6). On december 23, 2004, the wcribma formed workers' compensation rating and inspection bureau of massachusetts veba, which later became known as wcribma-veba.”

“Each year at the wcribma's annual meeting, the members elect at least nine but no more than eleven member representatives to serve on the governing committee. The elected governing committee members then appoint no fewer than three non-member representatives, consisting of one labor representative, one employer representative and one agent/producer representative, to serve on the governing committee.”

“The members of the wcribma need to approve any proposed amendments to the wcribma's constitution. This would be done at a meeting of the wcribma's membership. Additionally, at each annual meeting, the members of the wcribma are asked to ratify, confirm, and approve all acts of the governing committee during the preceding year. The massachusetts division of insurance approves amendments to the wcribma constitution.”

“The wcribma's budget committee, appointed by the governing committee, reviews a final form of the form 990 prior to actual filing. Members of the external audit and tax firm (currently aafcpas) initially discuss, prepare and review the return with the management team of the wcribma. Once the tax return is fully analyzed and reviewed by the management team, a copy is distributed to the budget committee members in advance of a specified meeting. Subsequently, aafcpa's tax group representatives meet with the management team and members of the budget committee in order to ensure all persons have had an opportunity to ask questions and discuss the content of the tax return,prior to the deadline. After the budget committee members complete their review and approve the form, it is sent to the entire governing committee for its review and comment prior to the filing of the form.”

“The organization's trustees and plan committee members are officers and/or employees of the wcribma and therefore follow the wcribma's conflict of interest policy. The wcribma maintains both a conflict of interest policy for employees, and a conflict of interest policy for officers and members of the governing committee (collectively "policies"). Under these policies, employees, officers and members of the governing committee are required to execute (and submit to the wcribma's general counsel) an annual disclosure statement which states that they received, read, and understand the conflict of interest policy. They agree to comply with the policy and disclose any conflicts or acknowledge that they have nothing to disclose which is in conflict with the established policy. Should any change occur in their situation, they shall submit a further disclosure statement covering the same. Once each year the wcribma's general counsel will also remind employees, officers and members of the governing committee of their obligation to submit a further disclosure statement if any change occurs in their situation. If any annual statement contains a disclosure of a conflict, or if a further statement is submitted, the general counsel will follow the procedures set forth in the policies.”

“A description of the organization's conflict of interest policy and the financial and governing information of the organization are reported in the form 990, which are available upon request.”

“The organization's trustees and plan committee members are officers and/or employees of the wcribma and therefore follow the wcribma's whistleblower policy. Under this policy, employees are required to report any violations or suspected violations of any applicable law or regulation or any wcribma policy. The policy states that the individual reporting such violations will be protected from retaliation; and identifies those individuals to whom such information can be reported.”

“The organization's trustees and plan committee members are officers and/or employees of the wcribma and therefore follow the wcribma's record retention and destruction policy.”