Hampden County Retirement Board Travel Regulations

Regulations accepted by the board and approved by PERAC

Regulations accepted by the board and approved by PERAC

Approved Date August 31, 2021

A. Purpose.

1. The Hampden County Regional Retirement Board (“HCRB”), in accord with guidance from the Public Employee Retirement Administration Commission (“PERAC”), recognizes that Retirement Board Members and the Retirement Board Staff must perform their fiduciary duties in an efficient, effective, and informed manner.
2.  The HCRB and PERAC Guidance recognizes the importance of continuing education; the need for informed decision making by Retirement Board Members; and the need for a broader public pension perspective, gained through association with other Retirement Boards and administrators, both within the Commonwealth of Massachusetts and throughout the nation.  These objectives can be accomplished with the assistance of reasonable, efficient, and effective travel and educational regulations.  The HCRB therefore, enacts this regulation to govern travel by Board Members and Staff Members of Retirement Boards.
3. These regulations are in addition to, and may, in some respects, be more stringent than the provisions of Chapter 268A.  Terms common to these guidelines and G.L. c. 268A shall have the meaning ascribed to them by G.L. c. 268A and rulings issued pursuant to that law.  Any previous Retirement Board Supplemental Regulations in effect shall be rescinded upon adoption and approval of these regulations.
4. All travel related expenses that are to be paid for by the Board shall be related to the purpose of the authorized travel and shall be cost-effective.

B. Authorization for Travel and Travel Related Expenditures.

1. Travel related expenses are to be approved by the Board in advance of the travel.
2. Requests for travel by Board Members shall be placed on a Board meeting agenda, discussed in open session, and approved by a majority vote of the Members of the Board present and voting.  The meeting minutes shall reflect the Board’s action and the extent of the authorization.
3. The nature of the travel, its purpose, and estimated cost shall be outlined on a travel authorization form.  The form must include a statement by the traveler, certifying that the expenses were incidental to the approved travel.  Brochures for seminars or other presentations should accompany the request for travel where available.
4. A statement describing the presentation, conference, or seminar should be entered into the minutes of the meeting following the travel.
5. A Board may authorize the Executive Director/Board Administrator to approve travel for other members of the Board’s Staff.  Guidelines for Board Staff travel should be developed and approved by the Board and must incorporate the provisions set out in these Guidelines.

C. Required Documentation for Reimbursement.

1. The method by which Board Members and Board Staff are to be reimbursed for travel related expenses requires completion of a form approved by the Board to be used in connection with the request that requires that the traveler certify that the expenses were incurred and were necessary and incidental to the approved travel.  The requests for reimbursement must be submitted within a reasonable time after the expenses are incurred, but no later than within 30 days.
2. Any requests for reimbursement should be completed and properly approved after incurring any travel, transportation, meal, or other travel related expenses and before reimbursement takes place.
3. Original itemized receipts must be submitted for all expenses including transportation, lodging, and other expenses incidental to travel.
4. Receipts are required for individual expenses over $10:  Travel-related expenses that are under $10 (such as gratuities) should be fully described and reimbursed based on the traveler’s certification that the expenses were necessary and incidental to the approved travel.
5. Any travel related expenditures which have not been properly documented or approved or are not in conformity with the Board’s regulations must be rejected or adjusted.
6. Reimbursement shall only be made to the person who actually made payment for the expense.
7. The reimbursement request form must be signed by the person seeking reimbursement and signed under the penalties of perjury.

D. Travel Arrangements.

1. The Board designates the Executive Director, or her designee, to be responsible for making all travel arrangements and for assisting Board Members and Board Staff in completing authorization and reimbursement forms.  When making travel arrangements, government rates or business rates will be secured.
2. An extended stay may be authorized if the net cost to the Board will be lower.  For example, if airline fare is lowered by staying an extra day and the cost of accommodations and meals for that extra day results in a net savings to the Board, payment for an extended stay can be authorized.

E. Transportation.

1. This regulation allows for airline, train, bus, automobile rental, taxi, or other form of public conveyance (as cost effective) to be utilized.
2. The Board recognizes that various modes of transportation may be utilized dependent upon the destination and the travel habits of the Board Members and staff persons.  Board Members and staff persons shall be reimbursed for the cost of transportation as noted herein.  Board Members may travel to educational conferences and/or seminars via airline, train, bus or personal automobile.
   
   a. When traveling by airline, the Board Member or staff person must book the lowest fare available at the time of booking, which shall not require more than one stop each way, which shall not require the Board Member or staff person to make more than one scheduled transfer between airplanes during any such trip and which shall have reasonable departure and arrival times.
   
   b. When traveling by personal automobile, the Board Member or staff person shall be reimbursed for mileage consistent with approved Internal Revenue Service regulations; provided, however, that if the cost for airline transportation and/or rental car, where appropriate, is less than the cost of the reimbursement for mileage, the Board Member’s or staff person’s reimbursement shall be limited to the cost of airline transportation and/or rental car.
   
   c. Payment of airline club memberships by the Board is strictly prohibited.
   
   d. The Board shall determine, on a case-by-case basis, whether a rental car is necessary and incidental to any particular Board related travel.  The source of such cars shall be a national rental agency and that the rental cars shall be “standard class”, although the Board Member and/or staff person may upgrade the vehicle at his/her own expense it is the traveler’s responsibility to verify that the rate charged is the rate negotiated.
   
   i. The Board Member and/or staff person shall accept the optional insurance coverage for any rental vehicle, and he/she shall be reimbursed for said expense.  Any motor vehicle accidents which occur while using a rental car on Board-approved travel must be reported as soon as practicable and in writing to the proper authorities.  Copies of any reports and/or documents filed in relation to said motor vehicle accident must also be filed with the Board.
   
   ii. The Board Member and/or staff person is personally responsible for any fines or other expenses related to traffic violations associated with Board travel.  All reasonable parking fees and tolls associated with Board-related travel shall be reimbursed.

 

F. Lodging.

1. All reservations for hotel accommodations should be made in advance, utilizing the single person, standard room rate.  If the Board Member or staff person is traveling with another person, any increase in cost for accommodation associated with the additional person shall not be borne by the Board.  The cost for any extended stay beyond that which is authorized shall not be reimbursed by the Board.
2. In a situation in which the cost for lodging is part of the registration fee for a conference or educational seminar, then the Board will not reimburse a Board Member or staff person for lodging.  If the cost of the lodging is separate and distinct from the registration fee for the conference or seminar, the Board shall reimburse the Board Member and/or staff person for the cost of said lodging at the standard room rate.  If the Board Member and/or staff person elects alternative lodging site not designated by the conference or seminar, the Board shall reimburse the Board Member and/or staff person in the amount not to exceed the daily standard rate as incorporated in the registration fee unless otherwise approved by the Board.

G. Meals.

1. Board Members and staff persons who attend educational seminars and/or conferences shall be reimbursed for the cost of meals upon production of the appropriate receipts.  The maximum daily reimbursable amount for meals shall not exceed $100.00.  If Board-related travel is to a high-cost location, the Board may review, on a case-by-case basis, any request for reimbursement beyond the $100.00 limit, and may reimburse Board Members and staff personnel, at its sole discretion, for daily meal expenditures in excess of $100.00.
2. In no event shall any Board Member or staff person be reimbursed for the cost of alcoholic beverages.
3. If reimbursement for meal expenses are sought by a Board Member or staff person for the payment of a meal of a third party or parties related to a business meeting, the individual or individual must be identified along with their affiliation.  Such third-party reimbursement for meals shall only be authorized in a situation in which the meal was part of a business meeting.  The meal reimbursement for such a business meeting shall be separate and distinct from the $100.00 daily meal reimbursement paid to the Board Member or staff person.  In a situation in which the cost of meals are included as part of the registration fee for a conference or seminar, a Board Member or staff person shall not be reimbursed for meals which are part of said package.  The Board recognizes that certain education conferences and/or seminars include the cost of some, but not all, meals.  In this situation, a Board Member or staff person shall be reimbursed as identified in the preceding paragraph for meals not included in the registration fee.  If the Board determines that special circumstances require a Board Member or staff member to take meals other than those included in the cost of registration, reimbursement may be made provided that all provisions of this regulation are met.  The special circumstances must be discussed in a Board meeting and the Board’s determination must be reflected in the minutes of the Board.

H. Other Reimbursable and Non-Reimbursable Expenses.

1. The Board authorizes other reimbursable expenses, requiring proper supporting receipts, including gratuities paid in accordance with local custom, telephone expenses limited to only Board or business-related calls, internet charges, costs for faxing, and costs for necessary copying.
2. The expenses that are not reimbursable include personal expenses, for example, in-room movies, mini-bar charges, gym fees, entertainment or recreational expenses, laundry and dry cleaning, and any payments for personal services.
3. The Board prohibits reimbursement for alcoholic beverages.

I. Cash Advances.

1. The Board prohibits cash advances in connection with anticipated expenses.

J. Board Credit Cards.

1. The Board authorizes usage of credit cards issued to the Board.  All personal use of credit cards issued to the Board is prohibited.  These regulations require that the credit card billings be issued to the Board office and that the card user be required to provide receipts for all expenses included in the statement.  If receipts are not provided, the user will immediately reimburse the Board for these expenses.
2. The credit cards are not to be used to purchase supplies or other items that the Board, the Board Members or the Board’s Staff use on a regular basis and which can be readily anticipated and purchased by way of a competitive process.

K. Personal Travel Combined with Board Related Travel.

1. If personal travel is combined with Board related travel, the personal portion of the trip will be clearly identified and paid for by the traveler.  Travel expenses or any other expenses incurred by a spouse, relative, friend, or other individual accompanying a Board Member or Board Staff Member will be considered to be personal travel and will, in no event, be a proper expense of the Retirement Board.

L. Payments or Reimbursements for Expenses by Third Parties.

1. These regulations prohibit the providing to or receipt by a Board Member or Staff Member of anything of substantial value from any person, firm, partnership, or other entity which may be reasonably expected to seek to do business with or is seeking to do business with or presently is doing business with the Retirement Board or any person, firm, or other entity that solicits or makes referrals or which may be reasonably expected to solicit or make referrals of any client on behalf of such a person, firm, partnership, or other entity.  The Board’s regulations prohibit the providing to and the receipt of anything of substantial value from such a person, firm, partnership, or other entity indirectly through any person, firm, association, organization, or other entity.
2. In instances where a Board Member or Board Staff Member participates in a legitimate speaking engagement, the Board shall pay all costs and expenses related to such speaking engagement, provided, that the Board Member or Board Staff Member complies with all of the Board’s travel regulations.  The Board may accept reimbursement for such travel related expenses of a Board Member or a member of the Board’s Staff from the third party, only under the following circumstances:
3. A Board Member or a member of a Board’s Staff may participate in legitimate speaking engagements in connection with their positions on the Retirement Board or as a member of the Board’s Staff and the Board may accept reimbursements from third parties necessary to cover travel related costs for such engagements.
4. Acceptance of an honorarium or any other form of compensation is strictly prohibited.
5. To be considered a legitimate speaking engagement, the presentation must be formally scheduled on the agenda of a convention or conference.
6. The speaking engagement must be scheduled in advance of the Board Member’s or Staff member’s arrival at the event.
7. The presentation must be before an organization that would normally have outside speakers address them at such an event.
8. The presentation cannot be perfunctory, but should significantly contribute to the event, taking onto account such factors as the length of the speech or presentation, the size of the audience, and the extent to which the speaker is providing substantive or unique information or viewpoints.
9. The Retirement Board can be reimbursed by a third party for expenses only to the extent necessary for making the speech or presentation.
10. Under no circumstances can a Board Member or Board Staff Member receive reimbursement or any other payment or compensation from a third party.

M. Due Diligence Travel.

1. The Board recognizes that as a fiduciary as defined in M.G.L. c. 32, s. 1, Board Members are required to discharge their duties for the exclusive purpose of providing benefits to members and their beneficiaries with the care, skill, prudence and diligence under circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims and by diversifying the investments of the system so as to minimize risk of large losses unless under the circumstances it is clearly prudent not to do so.  To that end, the Board recognizes that from time to time, Board Members may need to travel to observe the operation of a particular entity in which the Board has invested, or to ascertain whether a current prospective investment in a particular entity is or continues to be prudent under the circumstances.  In situations in which such travel is deemed appropriate and is pre-approved by the Board consistent with this travel regulation, a Board Member or Members shall be reimbursed for travel-related expense incurred as a result of such due diligence, provided that all travel-related expenses are submitted to the Board with the appropriate receipts and documentation.

N. Violation of These Guidelines or Board Travel Regulations.

1. The Board will review all circumstances pertaining to travel in accordance with the provisions of PERAC Guidelines.
2. Any person or entity that violates the PERAC Guidelines or Retirement Board regulations adopted pursuant to PERAC Guidelines and approved by the Commission shall be deemed to have violated the provisions of 840 CMR 17.00 and shall be subject to removal as a qualified investment manager or consultant pursuant to 840 CMR 17.04(10).  In the event of such a violation, the Board will not seek an exemption from the Public Employee Retirement Administration Commission pursuant to 840 CMR 19.02 or a qualification pursuant to 840 CMR 26.04.