April 11th Update: University Policy Review
This guidance provides for consistent and transparent guidelines and process for reviewing university policies to include development/updating, publishing, and implementation. The guidelines and process are intended to be efficient while allowing community input in the review of university policies.
Routine review of existing university policies is vital to ensure that they remain up-to-date, in compliance with changing laws and regulations, and continue to align with current operations and best practices. The Office of Ethics, Compliance, and Risk (OECR) is responsible for facilitating a routine review process with Responsible University Offices (offices that own and are responsible for implementing policies) to consider if policies in their area require No Changes, Minor Changes, Material Changes, or should be Eliminated. In instances where it is not clear if proposed policy revisions are minor or material, the draft will be brought to the standing Policy Approval Board (PAB) meeting for consideration and decision regarding change type. The outcome of the PAB review may kick off the policy review process outlined in this guidance.
This guidance focuses on the process for new and materially changed existing policies. Material changes include those that affect the university’s position or commitment, or spirit of the policy, because of changes in business principles, practices, or relevant laws and regulations. Minor changes to policies will be done administratively. Minor changes include edits such as updating job titles, phone numbers, e-mail addresses, website links, and office names.
This process also excludes revisions to codes and other governing documents which generally stipulate specific reviews and approval processes as well as procedural documents, standards, or practices as defined in Section 2. This exclusion includes the Faculty Organization Plan, the Faculty Code, the Code of Student Conduct, and the Code of Academic Integrity.
OECR is responsible for overseeing the execution of this process and the overall management of university policies. To enhance transparency in the overall university-policy landscape, OECR will post on its website an overview of all revisions to university policies at the conclusion of each semester.
University policies are created and maintained with the purpose of encouraging a culture of ethical, social, professional, and legal behavior and responsibility. They uphold GW’s values and mission while protecting its people and reputation. A university policy connects the GW mission to the everyday actions of its community and clarifies the institution's expectations of its individual members. Some university policies support compliance with applicable laws and regulations, while others outline the university’s commitment or community expectations on a specific matter.
Established University Policy Principles provide the standards and criteria for university policies. University policies have broad application throughout the university. They do not impact one singular unit but rather apply broadly to members of the university community such as faculty, staff, or students. University policies establish behavioral expectations for members of the community. These standards of accountability are a source of reference for individuals to assess whether if they are meeting those expectations. University policies are frequently enforceable through identified sanctions for policy violations so that members of the community understand potential consequences if established expectations are not met.
Departmental policies or procedural documents generally operate at a departmental level and provide detailed information regarding practices, standards, guidance, plans, or processes. Procedures are often methods established for implementation of a policy. If a policy is “what” the institution does, the procedures are “how” it carries it out. Documents that provide guidance on how a staff member is to perform their job in their unit are not university policies but rather unit-specific procedures and can be maintained by individual units. Additionally, there may be times that a unit wants to provide additional standards beyond what is articulated in a university policy. Unit standards do not replace or supersede university policies but rather complement and provide additional expectations for that specific area. These types of documents are often included in university policy through links.
The following process will be executed for new and materially changed university policies:
Note on Proposed Timelines: Completion of the full policy review process is likely to exceed 40 business days. The specific timelines described in this process may be extended by the PAB, by its own initiative, or in response to a request, if it determines that such an extension would benefit the policy review process. Requests for extensions can be sent to OECR.
This workflow captures the process and any relevant timeframes for new and materially changed policies (collectively “draft”).
University policies may be drafted and approved by the PAB 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 document. An interim policy will remain in effect until the final policy is fully adopted through this process or for up to twelve months from the implementation date, whichever occurs first. The PAB may renew an interim university policy, if necessary, based on their judgment. Notification including the rationale for the interim policy will be sent to the Executive Leadership Team, the FSEC Chair, and the Presidents of the Student Government Association and Staff Council, for distribution to their constituents as desired.
It is the responsibility of the Responsible University Office to identify if a policy in their area is no longer applicable (e.g., change in regulation or law, operations, or university expectations, or does not meet the criteria for what constitutes a university policy). The proposed elimination of a university policy will be brought to a standing PAB meeting for consideration and final decision. In cases where the elimination of a university policy is a recommendation because of material changes to an existing policy or development of a new policy, the recommendation for elimination will be included as a part of that policy’s draft development process and will only be eliminated once the draft is approved by the PAB through the established process in this document. OECR will publish on its website a list of eliminated policies in the overview of all revisions to university policies at the conclusion of each semester.
Policy Approval Board (PAB) is comprised of members of the university’s senior leadership including the Provost and Executive Vice President for Academic Affairs, Executive Vice President and CFO, Senior Vice President and Chief of Staff, and Vice President and General Counsel. The President will be included in PAB meetings for policies that require Board of Trustee approval governed by the established criteria. The Policy Owner/Responsible University Official are ad-hoc members of the PAB as appropriate. Additionally, the PAB may invite representatives of the Faculty Senate, the Student Government Association, and the Staff Council to participate in discussions on particular policies depending on the feedback received. The PAB will review the draft in consideration of the established university policy principles, its alignment with the university’s mission and values, and the policy’s necessity in supporting or enhancing the operations or compliance obligations of the university.
Responsible University Officials/Office (RUO) are owners of university policies. RUOs lead university units where policies exist to comply with laws or regulations, establish university expectations, and encourage a culture of ethical, social, professional, and legal behavior. RUOs are ultimately responsible for the content of the policies under their leadership and ensuring that said policies are not dormant but have active and thoughtful compliance plans. RUOs are essential in promoting a thoughtful policy review process and ensuring that the unit meets established policy review timelines.
Operational Policy Owners are staff who are responsible for the day-to-date execution and enforcement of university policies. As such, they are responsible for the review and edits (minor or material changes) of university policies and executing the compliance plans.
OECR is responsible for overseeing the university’s policy management program. This includes facilitating the annual review process, assisting in the drafting and editing of all new and amended university policies, supporting the university policy approval process as needed, including convening Policy Approval Board meetings, and maintaining the internal and external repository. OECR serves as a resource for questions regarding university policies and executing leadership’s vision for policies.