Dear Darla and Kellee: |
Below is a chart of the recommended retention periods for various Everett School Employee Benefit Trust (“ESEBT”) items. We can further discuss this at your convenience if helpful. |
Note that ESEBT Policy 450 (“Policy 450”) applies, and it references Board (School Board) Policy 8410 (Records Management and Retention) and Board Procedure 8410P (Records Management and Retention). It also references General Records Retention Schedule, School Districts and Educational Service Districts, provided by the Office of the Secretary of the State, Division of Archives and Records Management ( https://www.sos.wa.gov/_assets/archives/recordsmanagement/schools%20districts%20and%20esds%208.2.pdf ). |
Note that some of the periods below are longer than what is recommended in the Secretary of State policy, but I think these extended periods are important because the Trust is a VEBA and subject to other laws/requirements. |
Record Category
| Item
| Retention Period
|
ESEBT Board of Trustees Records
| Trust Agreement
Trust resolutions Board and committee meeting agendas and minutes | Permanent
Permanent Permanent |
ESEBT Finance and Administration
| Financial statements (audited)
Auditor management letters Check register and checks Bank deposits and statements Chart of accounts General ledgers and journals (includes bank reconciliations) Investment performance reports Experience-rated reports and corresponding data Equipment files and maintenance records Contracts and agreements, including contracts with ESEBT non-insurance services providers (if any) Contracts/policies of insurers that provide insured ESEBT benefits for active employees Contracts that provide non-insured ESEBT benefits for active employees Contracts/policies of insurers that provide insured ESEBT benefits for former employees Contracts that provide non-insured ESEBT benefits for former employees | 7 years
7 years 7 years 7 years 7 years 7 years 7 years 7 years 7 years after disposition 7 years after all obligations end 7 years after benefits are no longer provided 7 years after benefits are no longer provided 7 years after any participant or his or her surviving spouse, domestic partner, child, or other beneficiary is no longer eligible to receive benefits 7 years after any participant or his or her surviving spouse, domestic partner, child, or other beneficiary is no longer eligible to receive benefits |
Non-ESEBT Finance and Administration Insurance Records
| Policies — occurrence type
Policies — claims-made type | Permanent
Permanent |
Participant and Beneficiary Records
| Enrollment election, eligibility records and beneficiary designation for active employees
| 7 years after the participant (or beneficiary) is no longer eligible to receive benefits
|
Enrollment election, eligibility records and beneficiary designation for former employees
| 7 years after any participant or his or her surviving spouse, domestic partner, child, or other beneficiary is no longer eligible to receive benefits
| |
COBRA records
Benefit claim records | 7 years
7 years | |
Tax
| IRS exemption determination and related correspondence
IRS Form 990s Tax Records | Permanent
7 years |
HIPAA Privacy and Security Documents
| HIPAA privacy and security policies
HIPAA training materials HIPAA notices, including the Notice of Privacy Practices Authorizations for use and disclosure of PHI Records related to individual rights of access, amendment, accounting, restrictions and alternative communications Records related to complaints and violations of HIPAA privacy and security policies | 6 years after last in effect
6 years after last in effect 6 years after last in effect 6 years after last in effect 6 years after date created 6 years after date created |