Policy on Policies : University of Dayton, Ohio

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Policy on Policies

Purpose

The University of Dayton formally approves, issues, and maintains in a consistent format, official University Policies in a central policy library. Individuals engaged in developing and maintaining University Policies must follow the requirements outlined in this document for drafting, approving, revising, and withdrawing University Policies. University Policies must be thoroughly reviewed, maintained, and made available to the university community to promote, compliance, accountability, consistency, and fairness.

Scope

The entire University of Dayton community, including all employees, volunteers, visiting scholars, contractors, visiting researchers, consultants and other individuals who work for or visit the University of Dayton.

Policy History

I. Effective Date: September 9, 2014

II. Approval: January 9, 2023

III. Policy History:

Approved in its original form: September 9, 2014
Approved as amended: November 17, 2021
Approved as amended: January 9, 2023

IV. Maintenance of Policy: Vice President and General Counsel, Office of Legal Affairs

Definitions

(a) “Effective date” is the date on which the earliest version of a substantially similar policy that provides a policy statement for a particular topic went into effect.

(b) “Guideline” is a suggested course of action, an interpretation of University Policy through examples, or recommended best practices.

(c) “Maintenance of Policy” is the designation of a University official as being responsible for the general oversight of a policy that naturally falls within the official’s or office’s areas of responsibility. The responsible official may delegate operational responsibility to a policy owner. Depending on the scope of the subject matter, a policy may have more than one responsible officer, i.e., more than one policy owner.

(d) “Policy Owner” is the individual, department or unit, or office that has been assigned responsibility for maintaining a policy. This person may also be the individual who drafts a policy proposal.

(e) “Policy Title” is the official title of a policy.

(f) “Procedure” is a written statement that provides for the implementation of an established policy or other prescribed steps necessary to carry out management philosophy, guiding or governing principles and/or compliance with regulatory requirements and relevant law. A procedure can provide a process to accomplish tasks or reach a goal. University procedures may be limited to a department or unit and do not necessarily require formal approval, but they must remain consistent with University Policy.

(g) “Purpose” is a statement describing why the policy exists (i.e., mitigates institutional risk, supports institutional mission and values, meets legal or regulatory requirements of the policy).

(h) “Scope” is to whom a policy applies.

(i) “Statement” is a written communication from the Office of the President conveying an idea endorsed by the University or an official University position.

(j) “University Policy” is a written statement that provides direction and assistance to the members of the University of Dayton community in the conduct of University affairs. A policy is a written expression of management philosophy, guiding or governing principles, and/or compliance with regulatory requirements and relevant law.

(k) “University Policy Coordinating Committee” or (UPCC) is the body appointed by the President in May 2010 to serve as an advisory group to the President and the President's Council on all matters related to policies. The UPCC, led by the Office of Legal Affairs, has delegated authority from the President to establish University Policies and in doing so will strive to foster collaborative policy formulation. Membership of the UPCC will include at least a representative from each Vice Presidential area and the Academic Senate. The UPCC may monitor compliance, but responsibility for compliance with policies resides with individual Deans and Vice Presidents and their designees.

Policy

1. Introduction

University Policies align operations, set behavioral expectations across the University community, and communicate policy roles and responsibilities. Policy owners or drafters have the important task of reaching the intended audience with policies that are clear, easy to read, and provide the right level of information for the individuals specifically affected by the content. If users understand a policy, they are more likely to follow it and incorporate it into their daily work.

The University of Dayton uses a standard policy template that organizes the information in a consistent manner across all University Policies. This document and the attached appendices provide explanations and guidelines for each of the policy sections to make it easier to begin drafting policy and procedures.

The University Policy repository can be accessed at www.udayton.edu/policies and includes the official and current University Policies and related information. These policies and related information take precedence over inconsistent information from other sources, such as, handbooks, other publications, or other University websites.

The Office of Legal Affairs is available to assist University departments and personnel in their efforts to identify policy needs and draft policies that satisfy those needs. A Guide to Drafting University Policy is provided in Appendix A.

2. Establishing University Policy

The University Policy Coordinating Committee (UPCC) facilitates the approval process for all University Policies. For more information on the process for policy review and approval, see Appendix B.

University community members are encouraged to identify areas that may need a policy with University-wide applicability. Individuals interested in developing a policy should submit a proposal to and consult with their Division/Department Chair or Director. The Division/Department Chair or Director will evaluate the proposal and determine if it meets the criteria below.

The University of Dayton's policies reflect its philosophies, values and mission and provide guidance for decision-making and enforcement. The University establishes broad policies when appropriate in accordance with the criteria below.

A University-wide policy must:

(a) Mandate requirements of or provisions for members of the University community (at times the requirements may extend to external individuals who use University resources or services, as appropriate);

(b) Have broad application throughout the University;

(d) Be reviewed and approved by a committee of University administrative officers, typically the UPCC;

(e) Be sponsored and maintained by at least one University Vice President or designee;

(f) Help achieve compliance with any applicable laws and regulations.

Policy owners must consult with representatives from target audiences and/or core constituents during the development phase of both new and significantly revised policies. Individuals designated with policy maintenance responsibility must periodically review and monitor their policies and procedures for accuracy, efficiency, and effectiveness. Policy owners must also ensure that all monitoring and enforcement activities are appropriate for the level of risk managed.

3. Distinction Between University Policy and Department Policy

University Policies should be distinguished from procedures and practices and/or from policies within a department or unit. In the event of a conflict between a University Policy and a procedure, practice, or department or unit policy, the University Policy supersedes.

Departments or units may develop local policies, whether or not a corresponding University Policy exists. If a corresponding University Policy exists, they may adopt a more, but not less, restrictive local policy, except where a University Policy specifically prohibits units from establishing policies that differ from the corresponding University Policy or where the local policy runs counter to the purpose of the corresponding University Policy. However, to avoid confusion, departments and units should carefully consider the need to label such a document “policy,” and instead, use labels such as “process,” “protocol,” “guidelines” or “procedures” wherever possible to make clear that the document only applies to the particular department or unit.

Departments and units may not develop local policies that are inconsistent with the University of Dayton Constitution, Bylaws, policies, mission, or its Catholic, Marianist values.

University Policies and their subsequent revisions (other than updates to contact information) must be formally approved by the University President, and after they have been so approved, they have University-wide applicability and are enforceable.

4. Responsibilities

University President - officially approves all University-wide policies unless the Board of Trustees has reserved such authorization for itself. The President may present a proposed policy to the President’s Council for additional input, for their endorsement or to inform them of approved policies or a policy direction in general. The President maintains ultimate responsibility for all policies.

University Policy Coordinating Committee - serves as an advisory group to the President and the President's Council on all matters related to policies. A primary function of the UPCC is to facilitate discussion and consultation with any and all University units impacted or affected by a particular policy. The UPCC will work to accomplish the following:

(a) To inventory periodically and review all University Policies to provide consistency in the format, clarity in the substance of those statements and continued relevance and modernity.

(b) To discern and distinguish between University Policies, department and unit policies, procedures, protocols, guidelines or statements and prevent conflicts between them.

(d) To create and maintain an electronic and searchable repository to serve as the official location of all current University Policies and the resource of archiving prior versions.

(e) To develop and administer a process for proposing, formulating, vetting, approving, disseminating, amending, and deleting (when obsolete) University Policies.

(f) To assist in the communication, education, and enforcement of policies, procedures, guidelines or statements.

(g) To recommend processes for enforcement of University Policies.

(h) To ensure that University Policies, procedures, guidelines and statements are consistent with the mission of the University of Dayton and its Catholic and Marianist values.

Policy Owner – identify areas within divisions/departments that may require a written University Policy. The policy owner is responsible for following the guidance in Appendix A and the process outlined in Appendix B to draft and seek policy approval

5. Inclusivity

When University policies are developed and/or revised, care should be taken to ensure they are written using inclusive language, i.e., with an eye toward not using language that would exclude someone based on a Protected Class as that term is defined in the University’s Nondiscrimination and Anti-Harassment Policy. One example is using gender-neutral words. Approaches for this include using plural rather than singular pronouns; using a substitute in place of a gendered word (e.g., “spouse” instead of “husband,” “individual” instead of “him”); and using the passive voice or otherwise restructuring a phrase to avoid using a gendered word.

6. Savings Clause

Nothing in this policy is meant to preclude the involvement of the Board of Trustees and/or the Members of the Corporation in the policy development or approval process where such body desires such involvement.

Reference Documents

Appendix A

Guide to Drafting University Policy

The standard University Policy Template contains several sections that need to be included in any policy. Below are descriptions of each required section, as well as tips, samples and more.

POLICY TITLE

This section provides the official title of a policy. The title must identify the key purpose of the policy, in as few words as possible. The naming convention is the name of the policy (i.e., its subject), followed by the word "policy."

EFFECTIVE DATE

This is the date on which the earliest version of a substantially similar policy that provides a policy statement for a particular topic went into effect. The effective date of new policies or those that have substantially changed from previous versions should be the date that the current version was approved by the President, or when it is due to be implemented. (For example, certain new policies that may require significant cost expenditures for compliance may have a delayed effective date, where such delay is meant to allow for proper planning.)

APPROVAL

This section records the date on which the proposed version of the policy is most recently approved by the President.

MAINTENANCE OF POLICY

This section designates a University official (by position, not name) and office as being responsible for the general oversight of a policy that naturally falls within the official’s or office’s areas of responsibility. The responsible official may delegate operational responsibility to a policy owner. Depending on the scope of the subject matter, a policy may have more than one responsible officer, i.e., more than one policy owner.

PURPOSE

The information in this section answers the question as to why the policy exists. Key areas that may be addressed include:

legal or regulatory reasons
description of conflict or problem the policy will resolve
overall benefits
reasons related to the University’s Marianist mission

SCOPE

This section specifies to whom the policy applies. The scope answers the questions – who is the primary audience? Who needs to follow this policy? While University Policies by definition have University-wide applicability, they may apply more specifically to one or more particular groups. Examples: University staff, faculty, contractors, volunteers, undergraduate and/or graduate students, etc.

DEFINITIONS*

A list of unique terms that, by being defined, add to the reader's understanding of the basic policy or procedures. This is the appropriate section in which to define unfamiliar or technical terms, or terms with special meaning within a particular policy. The list of definitions should be posted in alphabetical order.

POLICY

This is the most important section of the University Policy. The policy itself – or, in other words, the University’s policy statement -- is ultimately a statement from the Office of the President conveying an idea endorsed by the University, or an official University position. It provides direction for the intended audience. Questions that are typically answered through the policy statement include: In what situation(s) does this policy apply? What are the major conditions or restrictions? What are the expectations of those affected? Are there exclusions or special situations?

Below are guidelines for the policy owner/drafter to keep in mind when drafting the policy statement:

Sentences and paragraphs must be clear and understandable for the given audience.
Acronyms may be used if spelled out completely the first time the phrase is used.

Example: University Policy Coordinating Committee (UPCC)

Use strong action words (will, must, are responsible for, etc.). Avoid using “shall” in the policy statement.
If the policy statement is lengthy or has different subsets, consider using numbering/lettering or some outline format to help guide the reader.
Use inclusive language.

What Not to Include

The policy statement should not include background details on the policy nor should it contain procedural steps. Procedures are a means of implementing policy and can be included, instead, in an appendix to the policy (with the intention that such appendix can be updated from time to time, as necessary); sometimes specific procedures may be left to the determination of a specific unit, department, or office.
Avoid using a specific label, such as the name of a software product. Generic terms are more sustaining and require less maintenance (i.e., less updating of the policy).
Similarly, avoid the use of individual names. Instead, use the more ambiguous or generic University office or position title.

Example: Use “University Mascot” instead of “Rudy Flyer.”

Avoid using specific contact information in the policy statement itself, unless required by law or regulation, or considered best practice. Contact information should be included in an appendix instead (with the intention that such appendix can be updated from time to time, as necessary).

REFERENCE DOCUMENTS

A list of resources that support the specific policy. These documents may be explicitly referred to in the policy or simply helpful to the readers’ understanding of it. The documents may be internal or external to the University, such as references to state or federal laws. Common examples are:

Related procedures;
Links to University-wide forms used/referenced in following the policy and associated procedure;
Handbooks that may contain additional information;
Related documents and sources of additional information, including final reports, meeting minutes, or other key background documents;
Citations to specific federal or state law or regulations.

The list of related information will be displayed in an order defined by the policy owner, typically in order by importance or level of involvement in the policy. Please be sure that any linked sites remain live. Outside websites should only be linked if you have confirmed that they are accessible (i.e., meet web accessibility requirements).

POLICY HISTORY

This section tracks the history and amendments to a policy since its original date of approval. Whenever possible, each subsequent approval date should be accompanied by a list of what changes and updates were made to the policy.

If the proposed policy is the first document addressing a particular subject matter, the text should read: “Approved in its original form: [Approval]”
Additional text may be included to clarify that the University had procedures in place to ensure compliance in a particular area prior to enactment of a University Policy.

Example: “The University-wide FERPA policy was first issued in March 2014; however, the University of Dayton has over the prior decades provided students their notification of rights by annually publishing those rights in the Student Handbook.”

APPENDICES*

More than one appendix may be attached to a policy, to house information that need not be included in the policy statement itself (i.e., a high-level pronouncement of a University’s philosophy on a matter) but rather is more procedural or informational in nature. For example, a process for implementing the policy may be included in an appendix, or contact information for those most involved in carrying out a policy or answering questions about it. Appendices can be modified from time to time, as needed, to reflect updated processes, changed contact information, etc., without going through the formal policy approval process (i.e., the President’s approval is not required to update an appendix).

* Section may be omitted when not applicable.

Appendix B

policy process

The following outlines the policy process beginning with a division/department assessment and ending with Presidential approval. These steps should be followed for both identification and drafting of new policies as well as amendments and updates to existing policies.**

Step 1: Division/Department Assessment and Audit

Periodically review University-wide policies in your area of responsibility. Determine whether:
- The policy is relevant, up to date, and currently in effect. If such is the determination, no additional steps are necessary.
- The policy is relevant and necessary, but needs to be updated or revised to better reflect actual University Policy or practice, to comply with certain regulations, and/or to correct referenced documents and/or websites to update them. If such is the determination, then:
  - In consultation with relevant campus constituents and the UPCC, make necessary revisions, being sure to use Word's tracking feature to track any changes to the policy as currently approved. (Keeping the changes in a tracking/redlined format enables UPCC and others to review them). Document reasons/justification for those changes.
  - Recommend that the policy be approved in its revised form.
- The policy is no longer relevant or in effect. If such is the determination, then formally recommend that the policy be removed from the University Policy and Procedures repository and be archived.
Identify any gaps or problems areas within your department that you feel or know should have the support of a University Policy.
- In consultation with relevant campus constituents draft a new policy that addresses the gap. Put the policy into the policy template and briefly note reasons that the policy is necessary.
- Recommend that the policy be approved and added to the University Policy and Procedures repository.

Step 2: Initial UPCC Review

UPCC reviews the Division/Department’s policy determinations and offers recommendations regarding campus stakeholders/constituents who should be consulted in reviewing an existing division/department policy or in development of a new policy.

Step 3: Division/Department Consultation

Division/department consults with relevant campus stakeholders/constituents per Step 2 above.

Step 4: Present to UPCC

Upon completion of consultation/review as set forth in Step 3, division/department presents those policies and corresponding recommendations to the UPCC for final review. (For simple updates to an existing policy, the multiple layers of UPCC review – i.e., Step 2 and Step 4, as presented here – may not be necessary.)

Step 5: Final UPCC Review

The UPCC will consider the submitted policies and incorporated feedback and affirms that the review process has been satisfactorily followed. The UPCC will recommend that the Division/Department submit the policies to the President for final disposition or recommendation for further action. After the UPCC has made its recommendation, no more edits should be made to the policy (other than formatting or clerical tweaks, or name/address updates) as the policy awaits the President’s approval. Note: If substantive changes are desired after the UPCC has already made its recommendation, then the additional changes should be sent to the UPCC for their review.

Step 6: Presidential Approval

The policy owner or VP for their unit under which the policy falls should present the UPCC-recommended policy to the President for approval. For the meeting with the President, the Office of Legal Affairs will provide a policy approval form for the President to sign. If the President so determines, the policy may also be shared with President’s Council.

Note that, for mere updates to the contact information in a policy, the President’s approval is not required. However, the President should be notified of the update.

Step 7: Recording

Upon approval, the Division/Department must report back to the UPCC with the final/official approval authority and date. This information will be incorporated into the final policy template and the policy will be published by the Office of Legal Affairs.

**In limited situations, certain policies -- including those mandated by federal or state statute, or the University President or Board of Trustees -- may be “fast-tracked.” A fast-tracked policy may not necessarily follow the above steps sequentially, but still requires adequate consultation with relevant University constituents and approval by the President.