Policies

Office of the General Counsel
Western Michigan University
Kalamazoo MI 49008-5200 USA
(269) 387-1900

Procedures and Submissions

Use this template for new policies

Policy Review Process

New Policies

  1. Units must work with the appropriate Vice President or equivalent, the President’s Office, or the Secretary of the Board (each, a "Sponsor") to identify whether there is need for a new or revised Policy or if an existing Policy should be rescinded. 
  2. Policies may have more than one Sponsor.  Sponsors may choose which area should be responsible for a particular Policy.  The President will resolve any disputes among Sponsors concerning Policy ownership.
  3. Prior to submitting a Policy to the University Policy Committee (UPC) for review, the Sponsor must do the following:
    1. Appoint a Responsible Enforcement Official (REO) to oversee the development, implementation, and enforcement of the Policy.  The REO will be the UPC’s contact throughout the Policy review and approval process;
    2. Work with REO to confirm that the document in question is a Policy, not a procedure or guideline.  See definitions in the Policy on Policies. Procedures/guidelines do not need to follow this process.
    3. Seek stakeholder input, including President’s Cabinet or Office of the General Counsel if necessary, on the Policy content and implementation plan; document which stakeholders were consulted and attach that documentation with submission to the UPC;
    4. Confirm either that the President’s Cabinet does not need to see the Policy or that the President’s Cabinet has already been informed of the Policy and has no concerns;
    5. Determine whether there are existing versions of Policies on the unit’s or others’ webpage(s) that should be removed;
    6. Identify existing/conflicting/outdated Policies elsewhere on campus;
    7. Ensure Policy is in the most recent version of the Board-approved template; and 
    8. Obtain Vice President (or equivalent) approval.

UPC Review of New Policies

  1. The steps set forth above must be completed before submitting the Policy to the UPC to review.  When the Sponsor and REO are satisfied with the form and content of the Policy, the REO will submit the Policy to the UPC via webform on Policies webpage.  The UPC may invite the REO to the committee meeting to answer questions about the proposed Policy.  
  2. Upon receipt of the Policy, the UPC will assign a member of the committee to be responsible for that Policy (Responsible Member).  The Responsible Member will usually be the member who represents the division that submitted the Policy.
  3. The UPC meets to review the proposed Policy for the following:
    1. Confirm that the REO obtained the necessary approvals;
    2. Format and content;
    3. Identify and address Policy conflicts and duplication;
    4. Identify existing, related Policies for revision or rescission consistent with the proposed Policy;
    5. Determine whether the proposed Policy requires Presidential or Board approval;
    6. Evaluate whether to obtain legal review and seek such review if necessary;
    7. Substantive review for the following:
      1. Submitted with necessary supporting documentation;
      2. Meets approved format;
      3. Supports the university’s mission, vision, and values;
      4. Applies across the institution;
      5. Establishes the university’s position across a range of matters;
      6. Endures across time and administrations, changes infrequently, and sets the course for the foreseeable future;
      7. Supports equity, integrity, and simplicity in practices across the institution;
      8. Promotes quality and operational efficiency, reduces bureaucracy, and provides guidance for managing the institution;
      9. Helps ensure compliance with applicable laws and regulations;
      10. Is consistent with university bylaws, rules, regulations, and existing policies;
      11. Is enforceable; and
      12. Helps reduce institutional risk.
  4. The UPC will make one of four recommendations:
    1. Proceed as written;
    2. Proceed with minor, non-substantive modifications;
    3. Return to submitter for additional considerations;
    4. Do not proceed.  One or more of the criteria set out above have not been met.  Additional committee review is required after changes have been made.
  5. The goal of the UPC is to obtain unanimous consent to move a Policy forward.  However, if all routes to agreement have been exhausted and there remains a disagreement within the UPC as to whether a Policy meets the criteria identified above, the Policy may move forward with a 2/3 majority of the Committee Members at the meeting so long as there is a quorum present.
  6. After review, and interactive communications with Sponsor if necessary, the UPC Chair or Responsible Member will post a copy of the proposed Policy to the UPC website for comments from the 51¸£ÀûÉç Community.
    1. The Responsible Member or UPC Chair will notify the university community that a draft has been posted.  Notice will be posted elsewhere as appropriate.
    2. University users will have a minimum of 14 business days to review and comment on the proposed Policy (the Committee may designate longer review periods as needed).
    3. Users with a valid BroncoNetID and password will be able to access and comment on draft Policies.  The UPC will make all efforts to keep commenters’ identities confidential.  Commenters may submit comments anonymously; however, doing so will limit the UPC’s ability to respond or collaborate with the commenter to address the concern identified.
  7. The UPC will consider submitted comments and may invite commenter(s) to a UPC meeting for further input.  Submitted comments are advisory in nature and do not obligate the UPC to make any changes in its recommendations regarding the proposed Policy.
  8. After considering any comments, the UPC will submit formal recommendations for changes, if any, to the Sponsor and assign the proposed Policy a number. 
    1. The first two digits of the Policy number correspond with the category to which it was assigned.  These are purely for reference. 
    2. The UPC will assign the second two digits sequentially unless the VP area has another organization system they prefer to use.  In that case, the Representative Member will inform the UPC of the numbering request.
  9. If the Sponsor makes any substantive changes based on the UPC’s recommendations or public comment, the Responsible Member will recirculate the new version of the proposed Policy to the UPC for review and comment.  If no substantive changes were made after prior UPC review, the UPC Chair will omit this step.
  10. If the Policy under review is a Policy that requires Board approval, the UPC chair will forward the Policy to the Secretary of the Board of Trustees so the Board may have an opportunity to review, comment, and ask questions about the Policy in advance of the Board meeting at which it will be considered.  If the Board requests substantive changes, the request will be forwarded to the Office of General Counsel to ensure that there are no conflicts or prohibitions regarding such change.  If there are none, the General Counsel will, in turn, forward the Policy to the UPC.
  11. The UPC Chair will then forward the resulting draft to the Sponsor for final approval.
  12. Once the Policy has been approved, the UPC Chair or designee will ensure that the new Policy is posted on the University Policies webpage.
  13. After final approval and posting, the REO or designee will:

    1. Link to Policy on own webpage (optional);

    2. Communicate existence of new Policy to stakeholders; and

    3. Initiate next review by date indicated in the new Policy.

UPC Review of Existing Policies

  1. Policies that have never received UPC review or have undergone substantive changes since prior UPC review must follow the process for new policies. Substantive Changes include:
    1. Changes due to law, rule, or regulation change;
    2. Changes that alter the meaning, scope, or application of the Policy;
  2. Policies that require minor, non-substantive changes do not need to follow the process outlined above and may be brought directly to the UPC.
    1. The Responsible Member must first have authority from the signatory of the Policy.
    2. The Responsible Member will summarize the proposed changes for the UPC’s consideration.  If the UPC agrees that the changes are non-substantive, the Responsible Member or designee will update the history section of the Policy accordingly and upload the revised Policy to CMS (or any successor system).
    3. Non-substantive changes include:
      1. Typographical, grammatical, or syntax errors;
      2. Changes in REO or signature authority;
      3. Wording changes that do not change the meaning, scope, or application of the Policy;
      4. Addition or deletion of references, citations, or hyperlinks.
  3. Policies that require no changes during regular review cycle

       a   Responsible UPC member will notify UPC that the REO has reviewed the policy and does not recommend any changes.

       b.  UPC will review to verify that they are aware of no changes needed within the context of the UPC substantive review criteria.

       c.   If no changes are recommended, REO or responsible UPC member will update revision history and proposed date of next review on policies website.

UPC Review of Policies Recommended for Rescission

  1. Responsible UPC member will notify UPC that REO has reviewed the policy, recommends rescission, and reason for recommendation.
  2. UPC will review for substantive review criteria and evaluate whether rescission will affect other university-wide policies. If rescission will affect other policies, responsible UPC member will work with REO of those policies to make any necessary adjustments.
  3. Upon completion of review and communication regarding policy rescission, responsible UPC member or REO will unpublish policy from university policies website.