University Policy on Policy Development
|Policy Title||Carnegie Mellon University Policy on Policy Development|
|Policy Owner||Secretary of the Corporation|
|Responsible Office||Office of the Corporate Secretary|
|Contact Information||Questions about Policy content should be directed to the Corporate Secretary, 412-268-6382.|
|Pertinent Dates||This Policy was approved April 1, 2015.|
|Appoved By||The president of Carnegie Mellon University.|
|Entitities Affected||All units of the university.|
|Who Needs to Know About This Policy||All members of the Carnegie Mellon University community.|
|Glossary||Definitions of terms used in this policy.|
|Related Information||Policy Content Checklist|
|Reason for Policy / Purpose||This Policy allows for a common, consistent and transparent process for all university Policies to be thoroughly reviewed, approved, implemented, maintained, communicated and made broadly available to the campus community. It is intended to be efficient and user-friendly. It serves to promote Policy awareness, compliance, mitigation of risks, accountability across the institution and supports a culture of risk-aware decision-making. Implementation of this Policy ultimately seeks to protect the university and its faculty, staff and students.|
||This Policy explains the process of how official university Policies are developed and approved.|
The university’s mission and values are expressed in and supported by its stated Policies. University Policies protect the integrity of the university’s mission, reputation and operations, and support the management of major institutional risks. They inform our community and third parties about the major risks that the university seeks to address and communicate risk tolerance in key areas. They also promote compliance with laws and regulations, especially those of the federal government. All university Policies (other than those which the ALC deems purely administrative in nature) must be developed, modified, approved and published in accordance with the standards outlined in this policy and must be published on the university’s central Policy website. University Policies must be kept current, reviewed on a regular basis, and made available to all relevant operating units in a timely manner.
Policy Review and Approval Process
The following process will be used for all University Policies (other than those which the ULC has deemed to be purely administrative in nature, consistent with the University’s historical practices).
- Using the standard Policy template and content checklist, the Policy owner develops a draft Policy or revises a current Policy (“Draft”) for which he/she proactively sought input from appropriate members of the university community knowledgeable about the subject. Policies should be drafted so that they are clear and concise and contain sufficient information on the subject without being excessive in length. If a Policy involves compliance with regulatory issues, the Office of General Counsel must review the draft. Careful consideration will be given, where applicable, to the education and training needs of the campus community as it relates to the Policy and/or Policy subject matter. The university policy coordinator will work with the Policy owner or other relevant parties to develop a Policy implemention plan, as well as a plan for education and training associated with the Policy.
- Once the Draft is approved for posting either by the Secretary of the Corporation or the ULC (whichever occurs first), the Draft is posted to the Policy website for a 30-day “Comment“ period. During this period, members of the University community will be able to submit comments about the Draft through the Policy website.
- The Policy Owner presents the Draft to the ULC for information and to solicit input. If the Draft has been posted to the Policy website prior to this meeting, the ULC also will be advised of any comments provided by the community. The Policy Owner will provide materials to assist the ULC members with presentation of the Draft to their relevant constituents. If the Draft has not been posted to the Policy website prior to this meeting, the ULC will direct the Policy Coordinator whether it is appropriate to post.
- Each ULC member communicates the Draft to his/her College/Division and other assigned constituents for feedback as relevant. Specifically, the Provost shall communicate with and seek feedback from Faculty Senate, the Vice President and General Counsel from the Staff Council, and the Vice President for Student Affairs from the Graduate Student Assembly and Student Senate.
- College/division feedback, assigned constituent feedback, and feedback from the Policy website are consolidated by the Policy Coordinator and given to the Policy Owner, who presents the information to the ULC. The ULC considers the Draft, decides whether to make revisions based on the feedback received, and makes recommendations to the President.
- The Policy Coordinator sends the final Policy recommendation to the president (and Board of Trustees, if required) for approval. If not approved, the draft will be resubmitted to the ULC for further revision and approval by the president.
- Upon the president's approval, the Policy Coordinator will work with the Policy owner to widely communicate, distribute, and publish the new Policy on the university's Policy website and advise faculty, staff, and/or students (as appropriate) on the availability of education and training.
- The first year after a new or revised Policy has been in place will be considered a beta test for the Policy. After the initial year the Policy owner, in consultation with the Committee on University Policy Development (CUPD), will review the Policy anew to determine if the implementation revealed any unintended consequences. If so, it will be reviewed and revised under these procedures.
- Some existing university Policies that precede the effective date of this Policy may contain specific requirements for approval of changes outside of the scope provided for in this Policy. In these cases, the specific requirements set forth in such Policies will be adhered to, and additional steps will be added to the process described above in order to comply with such additional requirements.
Exceptions to University Policies
While university Policies are expected to be followed by all university employees and faculty as applicable, an exception to a university Policy may be granted for good cause shown, such as unusual facts or circumstances that make adherence to the university Policy impossible or impracticable. An exception is ordinarily limited to the particular facts and circumstances giving rise to the request. Should the facts and circumstances indicate an issue that may recur or involves a broader issue, the Policy owner should consider revising the university Policy to avoid the need for future similar exceptions.
All exceptions must be requested and granted or denied in writing. Exception requests should be submitted to the Policy Coordinator who will facilitate its review by the Policy owner, consultation with the CUPD and/or the Office of General Counsel as applicable. (The Office of General Counsel must be consulted if there is any question whether the exception may implicate federal, state or local laws or regulations). The Policy Coordinator will maintain a record of any exception for precedential and audit purposes. No exception will be granted that may violate federal, state or local laws or regulations, including governmental rules relating to grants and contracts.
Policies may be drafted and approved by the president on an interim basis in situations where a university Policy must be established in a time period too short to permit the completion of the process delineated in this Policy. An interim Policy will remain in force until fully adopted through the process defined in this Policy or for up to six months from the date of issuance, whichever occurs first. The president may renew an interim Policy only if required to avoid violating federal, state or local laws or regulations while completing the process delineated in the Policy.
Existing university Policies, both formal and informal, including existing guidelines, will be systematically reviewed by CUPD and Policy owners in order to determine whether (a) each is still needed; (b) updates or other changes are needed; and (c) there are gaps that indicate where a new Policy should be developed. The results of this ongoing review willl be communicated to the ULC on a quarterly basis and, as completed, to each relevant unit where action is recommended. At the beginning of each academic year, a list of Policies scheduled to be reviewed or developed in that year will be published on the university Polices website.
The Policy Coordinator will facilitate education and training on this policy.