Guidelines for University Policy Review Process

 

Section 1: Introduction

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. 

 

Section 2: University Policy vs. Procedural Document

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. 

 

Section 3: University Policy Review Process

The following process will be executed for new and materially changed university policies:

  • Step 1 - Drafting: Using the standard university policy template, the Responsible University Office drafts a new policy or offers material changes to an existing policy (collectively “draft”) and identifies the rationale for the draft. OECR and the Office of the Vice President and General Counsel (OGC) are resources to be engaged in the drafting process to support process consistency, compliance with applicable laws and regulations, and linkages between relevant university policies. Policy draft proposals are ultimately the responsibility of the Responsible University Official.  
     
  • Step 2 - Pre-vetting Review: The draft with the supporting rationale will be brought to the Policy Approval Board (PAB) meeting for a pre-vetting review. The PAB will review the draft in consideration of the established 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. If in its review, the PAB determines that the draft is not needed or does not align, support, or enhance the mission, operations, and compliance obligations of the institution, the draft will not move forward. The Responsible University Official is an ad-hoc member of the PAB and updates to the draft may be made because of the PAB’s pre-vetting review.  If the review yields approval by the PAB to proceed, the draft will be advanced for GW community comment.  
     
  • Step 3 - GW Community Comment Period: University policies that have received PAB’s go-ahead will be posted publicly for the GW community to review and provide feedback. The GW community includes all faculty, staff, and students. Five (5) business days prior to the public announcement that a policy draft is posted for review and comment, OECR will notify the heads of the Faculty Senate Executive Committee (FSEC), Student Government Association, and Staff Council so they may circulate this policy draft within their organizations as they deem appropriate. OECR will also notify members of the Executive Leadership Team at this time. After this 5-day pre-notice period, a public notice will be published in GW Today. Policy drafts and a mechanism for community members to submit feedback will be posted on OECR’s policy website for 30 business days. More than one policy can proceed in this pathway at any given time.  

    Should the FSEC refer a policy draft to a standing committee of the Faculty Senate, the Provost will arrange for that committee the opportunity for a briefing on the draft with the Responsible University Office.  

    Should Faculty Senate, the Student Government Association, or the Staff Council adopt an official resolution or report about a policy draft, it will be delivered in whole to the PAB and not incorporated into the thematic summary of community feedback.

    View the Draft Policies Currently Open for Feedback
     
  • Step 4 - Feedback and Revision: All feedback from the comment period will be compiled and evaluated by OECR and the Responsible Office, which will then be responsible for reporting back to the PAB on any proposed revisions to the policy draft. OECR shall also prepare a thematic summary of the feedback. The PAB will periodically review all feedback received on a draft to ensure it is receiving an accurate summary. Following review by the PAB, OECR will send to the heads of the Faculty Senate Executive Committee, Student Government Association, and Staff Council the summary and current draft. This notice starts a five (5) business day period in which these groups may provide additional feedback.  
     
  • Step 5 - Final Review: At the end of this period the PAB will then make its final decision as to whether or not to approve the policy. A summary of feedback and the final policy decision will be posted to the policy website and delivered to the heads of FSEC, the Student Government Association, and Staff Council to circulate within their organizations.
     
  • Step 6 - Publish and Implement: When the PAB approves the final draft, the policy will be considered final and will be posted to OECR’s public university policy repository. OECR will work with the Responsible University Office to implement the policy’s compliance plan. The compliance plan outlines the steps to be taken by the Responsible University Office to execute the policy including procedures, training, communications, supporting resources, and enforcement.

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.  

 

University Policy Review Process Workflow

This workflow captures the process and any relevant timeframes for new and materially changed policies (collectively “draft”).

  • Responsible Office drafts a new or materially changed existing policy
    • Draft Policy brought to the Policy Approval Board (PAB) for pre-vetting
      • PAB determines that the draft will not progress forward [STOP]
      • PAB determines that the draft will advance for community comment
    • Notice of draft open for comment to heads of SGA, Staff Council, and Faculty Senate; ELT
    • GW Today notice of draft open for comment
    • OECR receives and compiles feedback; consults with PAB for revisions to be made to draft
    • OECR receives and compiles additional feedback
    • Final draft and thematic overview of substantive feedback brought to the PAB
      • PAB does not approve that the draft progress forward; Either [STOP] or back to a previous step
      • PAB approves draft or makes further revisions that once made would yield approval
    • Overview of PABs decision and approval status is posted to policy website
    • Final policy posted to OECR website repository; monthly public notice of all policies that have been reviewed

Section 4: Interim Policies

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. 

 

Section 5: Eliminating a University Policy

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.  

 

Section 6: Definition of Roles 

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.