Policies Every Booster Club Should Adopt: The Written Essentials

Why Written Policies Matter

The IRS asks about them. Form 990, Part VI asks whether the organization has a written conflict of interestConflict of interestA situation in which an officer, director, or committee member could benefit personally from a club decision. A conflict of interest policy requires the person to disclose it and step out of the decision.All terms policy (line 12a), a written whistleblower policy (line 13), and a written document retention and destruction policy (line 14). The instructions say to answer “Yes” only if the governing body adopted the policy by the end of the tax year and it applied to the whole organization. Clubs that file Form 990-N or 990-EZ do not answer these questions, but should still have the policies.

The IRS encourages them. IRS Publication 4221-PC states that the tax code does not require governance policies, but that the IRS encourages boards to consider policies on compensation, conflicts of interest, investments, fundraising, documentation of governance decisions, document retention, and whistleblower claims.

Some states require them. According to the New York Attorney General, New York requires nonprofits to have a written conflict of interest policy and requires larger nonprofits with employees to have a whistleblower policy. Requirements vary by state; see the club’s state page.

The Six Core Policies

Conflict of Interest Policy

The conflict of interestConflict of interestA situation in which an officer, director, or committee member could benefit personally from a club decision. A conflict of interest policy requires the person to disclose it and step out of the decision.All terms policy defines a conflict, requires each board member to disclose interests annually, and requires an interested person to leave the discussion and the vote. Booster Club Conflict of Interest Policy includes a full sample adapted from the IRS sample policy.

Whistleblower Policy

The Form 990 instructions describe a whistleblower policy as one that encourages staff and volunteers to come forward with credible information on illegal practices or violations of adopted policies, specifies that the organization will protect the person from retaliation, and identifies the people to whom reports can be made.

The instructions also note that while the federal Sarbanes-Oxley Act generally does not apply to tax-exempt organizations, two of its provisions do: criminal liability for retaliating against whistleblowers who report federal offenses (18 U.S.C. 1513(e)), and for destroying records with intent to obstruct a federal investigation (18 U.S.C. 1519).

In a booster club, the person most likely to notice a problem is a volunteer counting the gate, or a parent who sees a check that does not match an invoice. Without a policy, that person has nowhere safe to go when the problem involves an officer.

Sample whistleblower policy. Any member, volunteer, or officer of [Club Name] who reasonably believes that a club officer, volunteer, or contractor has acted illegally or violated a club policy may report it to the president. If the report involves the president, it goes to the vice president or the chair of the financial review committee. Reports may be made in writing and may be anonymous. The person receiving the report informs the board (excluding anyone named in the report) and the board investigates promptly. No one who makes a report in good faith may be removed from a position, excluded from club activities, or otherwise retaliated against. Anyone who retaliates is subject to removal under the bylaws. The board records the report and its resolution in confidential minutes.

See Preventing Embezzlement in Booster Clubs for what to do when a report involves missing money.

Document Retention and Destruction Policy

The Form 990 instructions describe a document retention and destruction policy as one that identifies the record retention responsibilities of staff, volunteers, board members, and outsiders for maintaining and documenting the storage and destruction of the organization’s records. The policy:

1. Adopts a retention schedule listing each record type and how long it is kept.
2. Names the officer responsible for each category (usually the secretary and treasurer).
3. Requires club records to be stored in club-owned locations, not personal accounts.
4. Sets how records are destroyed (shredding paper, deleting files) and requires a log.
5. Suspends destruction of anything related to an investigation, audit, or lawsuit.

Booster Club Records and Document Retention has a full retention schedule.

Expense and Reimbursement Policy

The expense policy prevents the most common booster club money disputes. It typically requires:

1. Purchases over a set dollar amount to be approved in advance by the board or the officer the budget names.
2. Itemized receipts for every reimbursement, submitted within a set number of days.
3. A second officer to approve every reimbursement; no one approves a payment to themselves or a family member.
4. Use of the club’s sales tax exemption certificate only where state law allows. See Sales Tax for Booster Clubs.
5. No personal purchases on club accounts and no club purchases on personal accounts without approval.
6. No debit cards, or strict limits if the board allows them.

See Booster Club Reimbursements and Expense Policy for a full sample.

Gift Acceptance Policy

A gift acceptance policy decides in advance which donations the club accepts, so a volunteer is not deciding on the spot whether to accept a used trailer or a gift for one student. It typically covers:

• What the club accepts: cash, checks, online gifts, in-kind goods and services useful to the program, and sponsorships under the club’s sponsorship terms.
• What requires board approval: vehicles, real estate, securities, gifts with restrictions, and anything requiring storage, insurance, or maintenance.
• What the club declines: gifts earmarked for a specific student, gifts that require the club to endorse a product or candidate, and gifts the school would not accept.
• Restricted gifts: the club accepts a restriction only if it can honor it, records it, and spends the gift only for that purpose.
• Noncash gifts over $5,000: when the club signs Section B of a donor’s Form 8283 (for donated property over $5,000) and then sells or disposes of the property within three years, it must file Form 8282 with the IRS, generally within 125 days of the disposition. The policy assigns this to the treasurer.
• Acknowledgments: who sends the receipt and what it says. See Donation Receipts and Acknowledgment Letters.

Gifts for a named student raise private benefit problems that can endanger exemption. See Private Benefit, Inurement, and Individual Fundraising Accounts.

Social Media and Communications Policy

The communications policy covers:

1. Who may post on behalf of the club, and that at least two officers hold administrator access to every account.
2. That accounts are registered to club email addresses, not personal ones.
3. Photo permissions: no student photos unless the family has consented, and no tagging of minors.
4. No fundraising for individual students and no posts that imply the school or district endorses the club without permission.
5. How negative comments are handled and who responds.
6. That no one speaks for the club to the press without the president’s approval.

See Social Media for Booster Clubs.

Other Policies Worth Considering

• Cash handling: two-person counts, count sheets, deposit deadlines. See Handling Cash at Booster Club Events.
• Volunteer screening and youth protection: which volunteers need district clearance. See Risk Management for Booster Clubs.
• Reserves: how much carryover the club keeps. See Booster Club Reserves and Carryover.
• Member data privacy: who may access rosters and how contact data is used.

How to Adopt a Policy

1. A board member drafts the policy, starting from a sample.
2. The secretary circulates the draft with the meeting notice.
3. The board discusses, amends, and votes.
4. The secretary records the vote and attaches the full text to the minutes.
5. Each officer signs an acknowledgment that they have read it.
6. The policy is filed in the permanent file and the relevant procedure books.
7. The board reviews every policy annually and records the review.

Policies adopted by the board are distinct from bylaws, which usually require a membership vote to change. See Standing Rules vs Bylaws.