Determining the Frequency of Fiduciary Committee Meetings for Health and Retirement Benefits Plans

The frequency of fiduciary committee meetings for both health benefits and retirement benefits plans can vary widely, depending on several key factors. These include the size and complexity of the organization, the nature of the fiduciary responsibilities, and any pertinent legal or regulatory requirements. To effectively fulfill their duties, it is generally recommended that fiduciary committees meet regularly [1] [2]. Here are some essential considerations regarding the frequency of these meetings:

Regular Scheduled Meetings: Fiduciary committees typically establish a regular meeting schedule, such as monthly, quarterly, or semi-annually, to ensure consistent oversight and decision-making. Regular meetings provide opportunities to review and discuss pertinent matters related to both health and retirement benefits plans, monitor plan performance, and address emerging issues [3]. For instance, quarterly meetings might be suitable for a committee overseeing a moderately complex retirement plan, while a large health benefits plan with frequent changes might necessitate monthly meetings [4].

"Although ERISA does not specifically state how often designated fiduciaries must meet to perform their duties, most retirement plan committees meet quarterly." - Christine Moehl, Saalfeld Griggs PC [5]

Legal and Regulatory Requirements: It is crucial for fiduciary committees to be aware of any legal or regulatory requirements that dictate the frequency of their meetings. For example, the Employee Retirement Income Security Act (ERISA) in the United States may prescribe specific meeting requirements or intervals for certain types of benefit plans. Compliance with such requirements is essential to avoid legal repercussions and ensure the fiduciary duties are being met.

Plan Activity and Complexity: The level of activity and complexity within the benefits plans significantly influences the frequency of fiduciary committee meetings. If a health benefits plan undergoes significant changes, such as modifications to plan design, vendor selection or changes, investment decisions, or regulatory updates, more frequent meetings may be necessary. Similarly, for retirement benefits plans, changes in investment options, participant demographics, or regulatory landscapes may require additional meetings to ensure all aspects are thoroughly addressed.

Ad Hoc Meetings: In addition to regular meetings, fiduciary committees may hold ad hoc meetings to address urgent or time-sensitive issues that arise between scheduled meetings. These meetings are vital for prompt decision-making and response to critical matters that cannot wait until the next regular meeting. For example, an unexpected regulatory change affecting retirement benefits may necessitate an immediate meeting to discuss compliance strategies.

"In addition to regularly scheduled meetings, the Chair of the committee should have the authority to call interim meetings. Interim meetings are often necessary in the event of sudden market shifts or company transactions that affect the plan." - Christine Moehl, Saalfeld Griggs PC [5]

Meeting Minutes and Documentation: Regardless of the meeting frequency, maintaining accurate meeting minutes and documentation is crucial. These records should capture key discussions, decisions, action items, and any dissenting opinions. Proper documentation demonstrates compliance with fiduciary duties and provides a historical record of the committee's activities. This practice is not only a regulatory requirement but also a best practice for transparency and accountability.

Ultimately, the frequency of fiduciary committee meetings should balance effective oversight with avoiding excessive administrative burdens. Committee members must assess their specific needs, legal obligations, and the evolving circumstances of both health and retirement benefits plans to determine the most appropriate meeting frequency. Regular communication and collaboration among committee members outside of formal meetings also contribute significantly to effective fiduciary governance. By staying proactive and adaptable, fiduciary committees can ensure they meet their responsibilities and safeguard the interests of plan participants.

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References:

 [1] John Hancock. (2024). What does a retirement plan committee do? Retrieved from https://retirement.johnhancock.com/us/en/viewpoints/erisa--plan-design/what-does-a-retirement-plan-committee-do

 [2] McKonly & Asbury. (n.d.). The Importance of a Retirement Plan Committee. Retrieved from https://macpas.com/the-importance-of-a-retirement-plan-committee/

 [3] John Hancock. (2024). What are some best practices for ERISA retirement plan fiduciaries? Retrieved from https://retirement.johnhancock.com/us/en/viewpoints/erisa--plan-design/what-are-some-best-practices-for-erisa-retirement-plan-fiduciaries

 [4] Anders CPAs + Advisors. (n.d.). Why Establish a 401(k) Committee Charter? Retrieved from https://anderscpa.com/401k-audit-committee-charter/

 [5] Moehl, C. (n.d.). Retirement Plan Committees - Helping Fiduciaries Sleep Well at Night. Saalfeld Griggs PC. Retrieved from https://sglaw.com/retirement-plan-committees-helping-fiduciaries-sleep-well-night/

U.S. Department of Labor. (n.d.). Meeting Your Fiduciary Responsibilities. Retrieved from https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/meeting-your-fiduciary-responsibilities.pdf

Society for Human Resource Management. (n.d.). Fiduciary Responsibility and 401(k) Plans. Retrieved from https://www.shrm.org/resourcesandtools/tools-and-samples/toolkits/pages/fiduciaryresponsibilityand401kplans.aspx

Vanguard. (n.d.). Best practices for plan fiduciaries. Retrieved from https://institutional.vanguard.com/content/dam/inst/vanguard-has/insights-pdfs/21_CIR_BestPrac.pdf

Willis Towers Watson. (n.d.). Best practices for retirement plan committees. Retrieved from https://www.willistowerswatson.com/en-US/Insights/2021/03/best-practices-for-retirement-plan-committees

Callan. (n.d.). Fiduciary Best Practices. Retrieved from https://www.callan.com/research/fiduciary-best-practices/

Mercer. (n.d.). Fiduciary Governance. Retrieved from https://www.mercer.com/our-thinking/wealth/fiduciary-governance.html

Prudential. (n.d.). Fiduciary Responsibilities. Retrieved from https://www.prudential.com/employers/insights/fiduciary-responsibilities