Compliance College-wide Policy Guidance

I. Purpose, Scope and Oversight

The purpose of this guidance is to provide the college community with a clear and consistent process by which to propose, develop, approve and disseminate administrative college-­wide policies (this policy is not intended to cover academic policies, which are within the purview of the faculty and the Provost and Dean of the College).

Senior staff members have the authority to enforce this guidance within their respective areas. Oversight of this guidance will be a shared responsibility of the General Counsel’s office and the area senior staff member.

II. Administrative Policy Development and Approval Process

All college-­wide policies should adhere to the standards and format set forth in this policy guidance to provide the college community with clear, concise and accessible expectations regarding how to carry out college activities. 

A. Determine the underlying need or justification for the policy (policies should be created when they define college values, institutional objectives or mandates; address federal or state law, regulations, or rules; or manage potential risk or liability).

B. New policies or changes to existing policies must be sponsored by a senior staff member who will appoint a responsible office or employee (Policy Owner) to develop the policy and forward the policy to the General Counsel’s office.  The Policy Owner is responsible for seeking input and from stakeholders.

C.  The Policy Owner should consult stakeholders in vetting of the proposed policy. If a proposed policy involves matters within the purview of more than one senior staff member, the Policy Owner should ensure consultation and coordination among appropriate leadership.

D. Policy drafting:

• Drafters should utilize this checklist.
• Policies should be drafted so that they are clear, concise and accessible and contain sufficient information on the subject without being excessive in length.

E. Early in the development stages, the Policy Owner should notify the college’s Compliance Director for technical assistance. The  Compliance Director can also assist with:

• Stewardship of the policy development process to ensure consistency with existing policies, language, clarity, format and appropriate vetting and approval;
• Consultation and engagement the General Counsel’s office, as appropriate;
• Review stakeholder and partner input.

F. The draft policy should then be reviewed by the General Counsel’s office.  In submitting the policy for review, it should be accompanied by an implementation plan, as well as a plan for any education, outreach and training associated with the policy.

G. Once reviewed, the General Counsel’s office will return the policy to the sponsoring senior staff member and Policy Owner with its recommendations and/or changes. The sponsoring senior staff member is the policy sponsor and has the ultimate responsibility of seeking approval for the policy from senior staff, including the President.  In some cases, the policy may be appropriate for a policy to be approved by the Board of Trustees. 

III. Post-Policy Approval 

After approval by senior staff and the President, the sponsoring senior staff member will be responsible for or will delegate oversight of the implementation plan, including coordinating publication and dissemination of the policy, and any related outreach and training efforts. 

A. Publication and Distribution of Policies: The college maintains a central policy webpage with links to college policies. Upon the approval of the policy, the sponsoring senior staff member or designee should coordinate with college Communications to publish and distribute the policy on the appropriate pages of the college’s website and by other appropriate means.

B. Review of Policies: The sponsoring senior staff member should ensure that college policies are current. To that end, the senior staff member or designee should: (i) conduct an initial assessment of a new college policy or major revision of a college policy one year after the effective date and or in accordance with applicable laws and regulations; and (ii) review the college policy periodically thereafter. The Compliance Director will work with the area senior staff or designee to establish a calendar for regular review of the policies.  The senior staff member or designee is responsible for updating the policy to address changes in applicable law or business practice. Material amendments to a policy must follow the same review and approval process outlined above.

IV. Decommissioning and Archiving Policies

If the senior staff member determines that a policy is no longer applicable or has been integrated into another policy, the senior staff member may propose that the policy be retired.

If a policy is retired, college Communications shall remove it from the website. College Archives will maintain an archive of all retired and previous versions of published policies.

Approved by Senior Staff on April 29, 2024