Develop and Maintain a UB Policy

A unit or individual determines the need for a university policy and obtains the agreement of at least one responsible executive (i.e., provost, vice provost or vice president) to take ownership of the policy.

Policy issues may emerge through federal or state legislation, State University of New York (SUNY) or Research Foundation (RF) policies, trends within or outside the university, a shift in university values or priorities, changes in best practices, concerns raised by the university community, an incident on campus or a variety of other ways.

A university policy is a directive that states the university’s official position on a particular issue. University policies endure across time and administrations and connect the university’s mission to individual conduct. University policies:

• Mandate actions or constraints for members of the UB community
• Have broad application throughout the university
• Help achieve compliance with applicable laws and regulations
• Support the university’s mission
• Promote quality and operational efficiency
• Help manage institutional risks
• Support equity and integrity in practices across the university
• Require presidential review and approval

A policy that does not meet all of the above criteria is a departmental, office or unit policy.

Departmental, office or unit policies:

• Address needs at the unit level or control issues that affect a subset of the university
• Apply only to the employees, staff, students and others within the issuing unit
  
• May create additional specifications, requirements or restrictions
  
• May not be more permissive than or contradict a university policy  

University policies must not be independently published or republished on departmental websites; departmental websites must link to the UB Policy Library.

The responsible office prepares the University Policy Proposal under the direction of the responsible executive.

The University Policy Proposal helps formulate:

• The need for a proposed university policy
• Whether the risk is sufficient to warrant the resources needed for policy development, implementation and maintenance
• Initial university legal review and guidance

University legal counsel will review the University Policy Proposal:

• For compliance with existing UB, SUNY and RF policies
• For compliance with applicable federal and state laws
• To identify potential legal risks that might arise from the use of a particular word, term, phrase or from any procedures included in or missing from the policy
• For general legal obligations
• To improve legal defensibility
• To ensure that it is in the overall best interest of the university

Good policy and procedure documents:

• Consider why the user needs the information
• Give the user the knowledge and security that the right things are done the right way
• Are written assuming the reader has:
  • Basic knowledge of the campus
  • Novice knowledge of the specific policy and procedure being described
    
• Use simple, clear, concise language – avoid jargon, legalese and overly technical descriptions
  • Use short sentences and common terminology
• Begin with a strong, clear policy statement
  • The policy statement describes what the rule is rather than how to implement the rule
    
• Are general enough to apply to unanticipated situations
• Differentiate between policy, background, procedure and other sections within the policy
• Include procedures and guidance as a link to a departmental website
• Provide accurate contact information
• Are reviewed regularly and updated as needed

Engage a group of individuals who are subject matter experts, policy users, stakeholders and others who will research and write the policy and procedures and provide feedback.

• Define roles and expectations for members of the policy writing group
  
• Establish a plan and time line for completion of the policy

• Determine if the proposed policy is needed in response to a:
  • Campus incident or problem
  • New or revised State University of New York (SUNY) policy
    • View the SUNY University-wide Policies & Procedures Library
  •  New or revised Research Foundation (RF) policy
    • View the RF Policies Library
  • New or revised state or federal regulation
  • Changes in customer needs, best practices, university culture, social trends
  • Another reason
• Review the University Policy Library to determine if existing policies address the issue
  • Could a related policy be expanded to include the information?
  • Could a related policy help inform the policy under consideration?
  • Cross reference rather than repeat information
• Review policies issued by SUNY, other SUNY campuses and other universities
  • Other campuses may have found new ways of addressing the issue
  • Other policies may help focus your policy development, provide a good starting point and suggest clear language
• Ensure that the university policy is in compliance with UB, SUNY and RF policies
  • A campus policy may be more restrictive, but cannot be more permissive than a UB, SUNY or RF policy
• Identify current processes, problem areas and the potential impact of any changes

Before you start writing:

• Think about the outcome you need to achieve
  
  • A strong, clear policy statement will provide direction or prescribe action
  • The policy statement describes what the rule is rather than how to implement the rule
• Research, analyze and read other policies, but don't just cut and paste sections from elsewhere
  
  • Be sure the document speaks with one UB voice
• Assess the audiences for the policy and write for a diverse audience, not the policy owner
  

Draft the policy using the University Policy Template.

The University Policy Template:

• Provides a framework for developing the policy and organizes content in a consistent manner
• Is structured so that the user can focus on the aspect of policy relevant to their decision

Assistance is available at any stage of the policy development process.
Contact Pam Lojacono for advice and guidance.  

Draft:

• Procedures required to implement the policy
  
• Guidance, if additional information or explanation is needed
• Forms, templates and related instructions required by the new policy
• Department web pages that will include the procedures, guidelines, forms and instructions; the policy includes a link the departmental website

Procedures are a set of instructions, steps or methods for the implementation, enforcement or administration of a university policy. Typically, procedures are:

• Action-oriented, step-by-step descriptions outlining who will accomplish a task, how it is performed and when it must be done
• Intended to ensure control activities are accomplished completely and consistently
• Not considered to be policy in and of themselves
• Created at the unit level
  • Changes do not go through the same review and approval process as policies
  • Procedures that impact multiple units may need additional review and feedback before being implemented

Guidance:

• Provides a framework within which to implement policies
• Includes general statements, recommendations, instructions or best practices to achieve policy objectives
• Can change based on the environment
• Should be reviewed frequently
  

The responsible office provides the draft policy, procedures and related documents to stakeholders (including vice presidents, deans and senior administration, as appropriate) who can offer a broad perspective on the content and application of the policy. After deliberating the feedback, the responsible office updates the draft policy and related documents.

Effective Stakeholder Engagement

Stakeholders are those individuals or work areas who may affect or be affected by a university policy. Stakeholders are likely to have distinct needs and levels of involvement, often with diverse and possibly conflicting interests and concerns.

Stakeholder engagement is about including the relevant people at the right time and in the most appropriate manner. All university policies have stakeholders with varying degrees of influence, involvement and interest.

Writing and consultation is often an alternating process, with the consultation informing the writing. Consultation is an important tool to:

• Test whether a proposed policy adequately addresses an issue and whether it is practicable
• Identify the competing interests of different people or groups
• Build consensus and a commitment to compliance with the eventual policy
• Support transparency in the policy development process
  

When executed effectively, stakeholder engagement can be used to:

• Gather information
• Obtain buy-in and ongoing support
• Build trust
  
• Improve communication
• Enhance reputation
• Lead to more equitable and sustainable decision-making
• Support ownership of the policy

When identifying stakeholders, it is important to think broadly to ensure all relevant stakeholders are recognized. Consider the following:

• Who is responsible for the policy
• Who is responsible for implementing the policy
• Who are the key representatives for those affected by the policy
• Why would a stakeholder want to engage in the policy process

Stakeholder engagement is an iterative process and should occur throughout policy development.

Stakeholder engagement is most effective when:

• Stakeholders recognize the mutual benefits of collaboration, for example, enhanced outcomes
• Early input and ongoing involvement in policy development ensure that the policy meets all needs rather than late engagement which can adversely impact time lines, implementation and working relationships
• Policy development is informed by practical needs (e.g., streamlining processes, enhancing administrative efficiencies and effectiveness)
• Stakeholders participate to identify and assess the operational impact and resource burden that implementation of the policy will place on units
• The method and time allowed for consultation is appropriate to the complexity and sensitivity of the policy

Some individuals may find it difficult to engage or circumstances may hinder them from fully contributing to the policy development process because of a lack of time or gaps in knowledge. However, it is important that the right people participate in the policy development process. Every stakeholder's perspective is valuable and will inform the end result.

Policy, Compliance and Internal Controls

The responsible office forwards the draft policy, procedures and related documents to Policy, Compliance and Internal Controls. Policy, Compliance and Internal Controls reviews the draft for clarity, coherence, structure, format, expression and other editorial aspects.

Policy Review Group

Subject matter experts and other members of the responsible office attend the Policy Review Group (PRG) meeting to discuss the policy, procedures and related documents and respond to questions. The PRG reviews the draft for understandability, practicality, implementability and potential impact.

The responsible office considers feedback, researches questions, and revises the draft policy, procedures, and related documents, as appropriate.

University community input and feedback are broadly sought, valued, and appropriately used. Policy, Compliance and Internal Controls posts the revised draft in 30-Day Review, an opportunity for the campus community to review and comment on new and revised policies. The responsible office considers the feedback received and revises the draft policy, as appropriate.

Policy, Compliance and Internal Controls forwards the final policy draft to university legal counsel for review and makes any recommended revisions.

Policy, Compliance and Internal Controls prepares the policy for presidential signature and forwards to the responsible executive.

The responsible executive signs the Presidential Signature Routing Slip and submits the final policy document to the president for approval.

The president reviews the final policy and upon approval, signs and returns it to Policy, Compliance and Internal Controls:

        Pamela Lojacono
        Policy, Compliance and Internal Controls
        420 Crofts Hall
        North Campus

The effectiveness of a policy depends on the extent of its reach and how well it is understood and followed. A communication plan helps achieve these objectives.

Policy, Compliance and Internal Controls:

• Publishes the approved policy in the UB Policy Library
• Works with the responsible office to issue an announcement to the university community
• Posts an announcement on the Administrative Services Gateway

Policy announcements can be:

• Distributed to various listservs (e.g., all employees; deans, directors, department heads; unit business officers; department specific)
• Discussed at department staff meetings

The responsible office:

• Implements education and training activities to achieve compliance with the policy
• Updates their website to include the:
  • Link to the policy
    
  • Procedures, guidance, forms and instructions related to the policy

The responsible office reviews their policy every three years, or more frequently as circumstances require. A comprehensive policy review is needed to determine if:

• The purpose and goal of the policy is still being met
  
• There are any new mandates (e.g., state or federal law changes) that require a policy change
• Changes have occurred in best practices, customer needs, university culture or social trends
  
• Changes are needed to improve effectiveness or clarify the policy or procedures
  
• The issue can be integrated with or addressed by other policies, rules or documents
• Terminology, contact information, websites and related links are current and correct
• The appropriate training and education is occurring
  
• The policy is still needed

When changes are needed, the responsible office follows the process to revise a UB policy.