"Section 139 disaster relief funds allow employers to make qualified disaster relief payments to employees ... [It] is prudent to set forth the terms of a disaster relief fund in a written document or policy ... [which] should describe the scope of the policy, the duration of the disaster relief fund, eligibility requirements for receipt of disaster relief payments, procedures to apply for payments, the timing and method of making payments, and limits on the amount of payments, if any.... A properly structured disaster relief fund will not be subject to ERISA."