990 Policies

By Rod McCullough, Past Chair, AACT Audit Committee

Three little answers to three big questions can mean a lot.

Specifically, when your organization completes its annual Form 990 to report to the IRS, it must answer these questions in Part VI, Section B.:

12a   Does the organization have a written conflict of interest policy?
13     Does the organization have a written whistleblower policy?
14     Does the organization have a written document retention and destruction policy?

If your organization answers "yes” and you’re happy with your policies, you need read no further. But if you answer 'no' or wonder about the quality of your policies, read on.  (Not so fast, those of you who file 990EZ or the postcard! You may not have to answer to the IRS, but you will want to be sure you have good policies in place.)

The AACT Audit Committee has researched and crafted a set of policies that could serve as models for member theatres, as well as AACT. AACT subsequently adopted those policies.

The policies listed below are valuable not just because adopting them allows you to answer "yes” to the IRS. Each one is an example of good governance that protects your organization before a problem occurs. Before a Board member attempts to change theatre purchasing so it benefits a friend. Before a staff member or volunteer is disciplined or blackballed because they informed the Board of an illegal practice. Before your Board discovers they can’t address a complaint because someone threw all the records away. And any number of other examples.

Here’s one more tip from the Audit Committee: Begin each of your board meetings with a call for conflicts of interest. It’s a reminder to board members of their responsibility and allows an opportunity for increased transparency – never a bad thing.

[Special thanks to Audit Committee members Jill Patchin and Bill Muchow (AACT past presidents) and Gary Walker (AACT executive vice president) for the research and drafting of these new policies, and to committee members Tim Jebsen and Jim Walker for refining the final product.]