Policy on the Development, Management and Approval of University PoliciesPolicy Number: 102
Governance and Legal
The permanent link for this policy is: https://policies.northeastern.edu/policy102/
I. Purpose and Scope
University policies promote the university’s mission, enhance operational efficiency and university governance, and communicate expectations relating to conduct. Northeastern University expects faculty, staff, students and visiting faculty and scholars, as well as volunteers and agents when they act on behalf of the university, to be familiar with and adhere to all applicable university policies.
In order to promote accessibility to current policies, as well as consistency and clarity of content, this policy establishes a framework, common format, roles and responsibilities and the process for development, adoption, review, revision, retirement, and dissemination of all university policies as defined in this policy.
This policy applies to all existing and proposed university policies, except that the approval process described does not apply to the Faculty and Student Handbooks, the Athletics Compliance Policies Handbook, or the Undergraduate and Graduate Catalogues, which follow their own approval processes.
For purposes of this policy:
A. Policy is a high-level statement of guiding principles and standards that articulates the institution’s values and communicates behavioral expectations and requirements related to a specific topic or area.
1. University Policy is one with broad application across the university, or to major components of the university, that enhances the university’s mission, fosters compliance with applicable laws, regulations, and/or internal standards, promotes operational efficiencies, and seeks to reduce institutional risk.
2. Unit-level Policy is that applies only to a specifc unit, or that is an internal operational policy for a specific division or department. Examples of unit-level policies include, but are not limited to, parking policies specific to different campuses or properties of the university, or dress or access policies specific to different lab/research areas at the university.
B. Procedures set forth identified steps for implementing a policy.
C. The Responsible Office/Department is the university office responsible for developing and administering a policy, which includes dissemination of the policy, development of procedures where appropriate, communications and training related to the policy, and timely revisions.
D. The Policy Oversight Committee is the standing committee comprising representatives from key areas across the university that has been established by senior leadership and charged with overseeing the policy process including proposals for new policies; review of policy drafts and revisions; advice to units on policy development; and facilitation of policy review and approval by senior leadership.
E. The Policy Template is the standard format that university policies must follow. It includes a short, descriptive title; statement of the purpose and scope of the policy; any applicable definitions and exclusions; the policy itself; and additional information, such as enforcement; and contact information for questions or guidance on the policy.
F. University Policy Manager is the individual within the Compliance Department responsible for serving as the primary administrator for the university’s policy development and management processes (including posting and archiving university policies); and supporting responsible offices in drafting, reviewing, approvals, updating, posting, and archiving university policies and applicable procedures.
A. Administration and Oversight of University Policies
1. Working through the Policy Oversight Committee, responsible offices/departments are charged with overseeing the initial development, regular review, and proposed revisions of university policies related to their area(s) of responsibility in accordance with this policy and established procedure.
2. The Chief Compliance Officer and University Policy Manager will:
a. Establish and manage an on-going policy review process for all active university policies (occurring at least every three years);
b. Maintain an archive of all university policy changes; and
c. Post procedures and other guidance for the implementation of this policy.
B. Development and Format
1. New university policies or policy revisions may be initiated by individual departments, colleges, schools, institutes, or other administrative or operating units.
2. Development of a new policy should be approved by the Policy Oversight Committee, generally in advance of drafting the proposed policy, through the submission of a policy proposal form, found on the policy website.
3. Each policy must follow the format provided by the policy template, should generally refrain from including procedures, and be drafted in clear concise language.
4. New university policies must be sponsored by the responsible office/department with oversight in that area, and must be approved by the appropriate university officer.
C. Review and Approval
1. The Policy Oversight Committee provides the initial review of draft policies, and may suggest or require revisions towards a final draft. Once a draft is considered final, the Policy Oversight Committee will facilitate its submission through the appropriate approval process.
2. All new policies and substantive revisions require the approval of the following:
a. For new policies – Approval by the President, Senior Leadership Team, or Board of Trustees where approval by the Board is required or appropriate.
b. For substantive revisions – Approval by the Senior Leader responsible for the area, or Board of Trustees where approval by the Board is either required or appropriate. The Policy Oversight Committee may recommend additional review or approval as may be appropriate.
c. For clerical/non-substantive revisions – Approval by the Chief Compliance Officer, in coordination with the Policy Oversight Committee. Clerical changes are limited to fixing broken links, updating titles, office names, or contact information, or fixing obvious errors.
3. Prior to submission for approval, draft university policies must be presented for legal review by the Office of the General Counsel, as well as review by any office(s) directly responsible for implementing a substantive aspect of the policy.
4. Where there are any objections that are not reconciled, the responsible office/department will note these reservations.
5. The final draft policy will then be submitted by the sponsoring responsible office/department to their area senior leader for final review before submission, as required.
6. New policies and policy revisions shall also include a proposed implementation and communication plan.
If training on a new policy or substantively revised policy is necessary or advisable, the responsible office/department will develop or identify, and provide or make available appropriate training for the university community or relevant sub-group within the university community, and will maintain training records, as appropriate.
E. Regular Review/Revision
1. The responsible office/department is responsible for regular review/updating of its policies and for timely revisions to reflect changes in applicable law that implicate provisions of the policy. At a minimum, policies should be reviewed and validated every three years.
2. Proposed revisions are subject to the requirements of this policy for drafting, formatting, review, and submission to the Policy Oversight Committee, as well as dissemination and training where appropriate.
3. The Compliance Department will archive previous versions of all policies.
F. Policy Retirement
If the responsible office/department concludes that a policy within its area has no continuing applicability, it may propose retirement of the policy through the same review and approval channels set forth in this policy. Retired university policies will be archived but will be available by request to the Compliance Department.
G. Unit-Level Policies
a. No unit of the university may adopt or maintain a unit-level policy that is inconsistent with, conflicts with, or appears to otherwise expands the obligations of the university beyond those set forth in official university policies.
b. No unit of the university may adopt or maintain a unit-level policy that imposes obligations on a unit not directly administered by the unit developing the policy. As an example, The Provost’s Office may develop unit-level policies for subordinate offices whereas the Athletics Office cannot develop unit-level policies which impose obligations on the Provost’s Office. Such policies should be submitted to the Policy Oversight Committee for review in accordance with this policy.
IV. Additional Information
Nothing in this Policy limits the authority of the university to issue, amend, or withdraw a policy.
Additional resources can be found on the University Policy website.
Procedures for Developing University Policies
Policy on Policies
Policies; Compliance; Procedure; Template
Last Revision Date: 2022-11-03