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 General Counsel|
|Contact Information||Questions about Policy content should be directed to the Office of the General Counsel, 412-268-3662.|
|Pertinent Dates||This Policy originally was approved April 1, 2015 and subsequently revised November 2019.|
|Entities 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 that the ULC 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 Policies 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 seeks input from appropriate members of the university community knowledgeable about the subject. The Policy Office posts notice that the Draft is being developed on the Policy website. The Policy Office notifies the Faculty Senate’s Executive Officer that the Draft is being developed, and requests to be informed of the manner in which the Faculty Senate wishes to provide input on the Draft, and informs the Policy Owner of any response received. 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 Office will work with the Policy Owner or other relevant parties to develop a Policy implementation plan, as well as a plan for education and training associated with the Policy.
- The Policy Owner presents the Draft to the ULC for information and to solicit input. Following ULC discussion of the Draft and incorporation of any changes recommended by the ULC, the Policy Owner will send a copy of the Draft to the Policy Office, which shall send a courtesy copy to the Faculty Senate’s Executive Officer for review by Faculty Senate. Faculty Senate may request briefing on the Draft by the Policy Owner, either before the Faculty Senate Executive Committee, in a Faculty Senate Meeting, or both.
- Contemporaneously, each ULC member will communicate the Draft to his/her College/Division and other assigned constituents for feedback as relevant. Specifically, the provost (or the provost’s designee) shall communicate with and seek feedback from Faculty Senate; the Vice President for Operations from the Staff Council; and the Vice President for Student Affairs from the Graduate Student Assembly, Student Senate and Student Body President.
- College/Division feedback and assigned constituent feedback are consolidated by the Policy Office and given to the Policy Owner, who presents the information to the ULC. The ULC considers the Draft, and decides whether to make revisions based on the feedback received.
- The ULC will direct the Policy Office whenever the Draft is ready to post to the Policy website for a 30-day “Comment” period. Once posted, during this period, members of the University community will be able to submit comments about the Draft through the Policy website.
- Feedback from the Policy website is consolidated by the Policy Office and given to the Policy Owner. If, as a result of the feedback, the Draft will have only immaterial changes, the Policy Owner sends the Draft to the president (and Board of Trustees, if required), with a cover memo stating that it is in the form presented to ULC with only immaterial changes, for approval. The president (and Board of Trustees, if required) may then approve or choose to send back to ULC for further consideration.
- If, as a result of the feedback, the Draft will have material changes the Policy Owner presents the feedback to the ULC. The ULC considers the Draft and decides whether to make revisions on the feedback received. The ULC, in its discretion, may direct the Policy Office to repost the Draft to the Policy website for an additional “Comment” period (which may be less than 30 days) or to approve it as revised. Once the ULC determines that the Draft is final, the Policy Office sends the final Policy recommendation to the president (and Board of Trustees, if required) for approval. If not approved, the Draft will be sent to the ULC for further revision and subsequent resubmission for approval by the president (and Board of Trustees, if required).
- Upon the president's (and Board of Trustees’, if required) approval, the Policy Office 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.
- Some existing university Policies that precede the effective date of this Policy may contain specific requirements for approval of amendments. In these cases, the specific procedural requirements for approval of amendments as set forth in such Policies will be adhered to.
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. Exceptions may only be granted by the president or provost. All exceptions must be requested and granted or denied in writing.
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 twelve months from the date of issuance, whichever occurs first. The president may renew an interim Policy if necessary in the president’s judgment.
Ongoing Policy Review
University Policies will be systematically reviewed by the Committee on University Policy Development (“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 will be communicated to the ULC on an annual basis and, as completed, to each relevant unit where action is recommended.
The Policy Office will facilitate education and training on this policy.
Decommissioning a University Policy
A Policy Owner who believes that a university Policy should be decommissioned may request CUPD to review such Policy for possible decommissioning. The Policy Owner seeks the consultation of each of the groups listed in Section 3 of Policy Review and Approval Process, and provides each with a statement of intent to decommission the Policy. The Policy Owner shares the results of the consultations with CUPD. On an annual basis, CUPD will present to ULC any university Policies it recommends for decommissioning. The ULC then decides whether or not the Policies should be decommissioned. If the ULC determines that decommissioning is appropriate, the Policy Office will be advised of the decision and will schedule the Policies for decommissioning.