When I initially started working with higher education clients to develop their policies, it quickly became evident that the typical higher education organizational structure leads to a “silo” approach to policy development.  That is, responsibility for managing policy tends to be distributed across several departments within the school, which in many cases function as independently operating “silos”.  This can result in several problems.  Most importantly, the institution runs the risk that policy development becomes a low departmental priority, thereby increasing the likelihood of non-compliance with U.S. Department of Education requirements, federal and state laws, and accreditation standards.  Enforcement may also be inconsistent and sporadic.  The “silo” approach also lends itself to informal policy coordination, resulting in an unclear understanding amongst campus members as to which policies apply to them and, perhaps even more dangerous from a risk management point of view, the development of inconsistent or contradictory policies.

Effectively run colleges and universities understand the pitfalls associated with the “silo” method and the importance of adopting a strategic approach to managing policies from an institutional perspective.  They regard as imperative a coordinated institution-wide response to policy development that ensures compliance with Department of Education regulations, federal and state laws, and accreditation standards.  Similarly, staff and faculty productivity, guided by well-written, compliant policies that are effectively communicated and consistently enforced, is viewed as vital to successful administrative and scholarly operations.

So, how do colleges and universities overcome the “silo” policy challenge?  From our perspective, there are four high level, basic principles that well-administered schools follow to effectively manage their policies:

• They create an institution-wide policy system;
• They develop a standardized, formal policy development and approval process that allows for a coordinated response to policy need;
• They draft well-written, consistent policies that address operational needs, Department of Education, legal, and accreditation regulations and standards; and
• They invest in a web-based application to facilitate the communication and updating of policies.

Formal Institution-wide Policy System

Colleges and universities with smooth administrative and scholarly operations design and maintain policy systems that facilitate policy coordination across the institution.  These systems serve to logically organize and make available institution-wide policies (those with broad application throughout the institution that require either board or trustee or presidential review and approval) in a central location––preferably via a searchable, web-based application.  In developing such systems, policies are more easily maintained and greater policy compliance is achieved as the campus community has improved access to policies.  Moreover, the risk for policy redundancies and contradictions is eliminated.  Consistency in presentation is also promoted and resources are potentially conserved.

To create such a system, an initial collection of the institution’s current policies from each “silo” of the institution needs to be undertaken.  There are a large number of policy sources to draw from and it is critical that the collection is comprehensive.  Once collected, the policies then need to be organized to minimize inefficiencies.  How a school chooses to organize its policies is institutional preference.  The key is to adopt an organizational system that is intuitive, logical, and easy to maintain.  At Stevens Strategy, we advocate a volume approach that systematizes policies according to broad policy topic areas such as governance, campus community (i.e., security, environmental safety, information technology, public relations, advancement), human resources, faculty, academic, student life, and business and financial affairs.

After the policies are organized, it is essential that they be audited for clarity, accuracy, and completeness.  There should be no policy redundancies or contradictions.  Current
policy should be consistent with actual school practices and presented in a uniform manner and tone.  Finally, and most importantly, there should be a determination as to whether current policies address and/or comply with relevant Department of Education regulations, accreditation standards, federal and state laws, and industry best practices.  Auditing should be performed by teams of dedicated staff with requisite expertise in a given policy topic area under the direction of area vice presidents or department directors.  Where applicable, legal counsel should be consulted.

Standardized Policy Development and Approval Process

Colleges and universities with smooth administrative and scholarly operations further ensure policy coordination across the institution through a standardized policy approval process.  The following factors are critical to their success:

• The process is inclusive and transparent;
• The process adheres to shared governance practices;
•  The process is consistently followed;
• Final policy approval rests with the Board of Trustees or the president (or designee) as applicable.

With these key success factors in mind, what does the typical policy approval process look like?  Schools have nuanced approaches, but, in general, three basic steps are followed:

1. Pre-Development Phase: The pre-development phase centers upon the identification of a need to develop a new policy or revise a current policy.  Any member of the campus community or existing body has the ability to submit a policy plan to either the president’s executive team or, if applicable, a standing policy committee.  If there is agreement to proceed with the policy plan, a policy owner(s) (i.e., administrator, standing committee, task force, etc.) is identified and assigned drafting responsibility.
2. Development Phase: In the development phase, the policy, under the leadership of the policy owner, is drafted.  Drafting best practices are followed and key stakeholders, committees or task forces, and/or governance bodies are engaged for input, comment, and, if applicable, approval.  In addition, policies of legal import are drafted in consultation with or vetted by legal counsel.
3. Policy Approval Phase:
   1. Once the policy is in final draft form, it is submitted to the president’s executive team or standing policy committee, which will review the policy for consistency in format and presentation, conflicts between the proposed policy and other school policies, consistency with laws or other external regulations germane to the policy, and compatibility with the school’s mission.  It then recommends the policy to the president for adoption; refers the policy for further development with suggested changes; or recommends to the president that the policy not be adopted.
   2. Upon receipt by the president, he or she approves the policy, refers it to the policy owner for further development with suggested changes, or decides not to approve the policy.
   3. Where required by the school’s bylaws, board policy, legitimate past practice, or decision of the president, the policy is then forwarded to the Board of Trustees for approval.
   4. Once approved, the policy is published in the school’s institution-wide policy system and, under the direction of the policy owner, training is conducted if applicable.
   5. Following training, the policy owner monitors the policy for compliance and reviews the policy according to an established review cycle.

Compliant and Well-Written Policies

The third key best practice followed by colleges and universities that most effectively manage their policies is to draft compliant and well written policies.  These institutions develop well-researched, benchmarked policies that are compliant with industry best practices and Department of Education, legal, and accreditation regulations and standards.  In drafting their policies, they use plain, easy to understand English in the active voice with commonality in presentation, tone, and definition.  Many larger schools utilize a standardized policy form.  Gender-specific references are typically avoided, as is legalese and colloquial phrasing.  Charts and graphics are commonly utilized to increase stakeholder understanding and related policies, typically through the use of hyperlinks, are cross-referenced.  Finally, the history of policy revisions is documented.

Web-Based Application

Finally, institutions that effectively manage their policies use a web-based application to publish their policies.  Such applications are user friendly, expedient, and include an advanced search component, resulting in improved efficiency and overall policy compliance.  Superior systems can also play a role in the policy development process.  Web-based policy systems are also environmentally friendly.

Stevens Strategy has recently partnered with IMPACT Management after witnessing first hand the efficiency and benefits of theirP2 Policy system.  For more information on the P2 System, email Stephen Lazarus.

Conclusion

Well-administered colleges and universities appreciate the role policies play in achieving their mission and have adopted strategies to manage their policies from an institutional perspective.  They focus on developing an institution-wide policy system that includes well-written, compliant policies and a standardized policy development and approval process.  They also invest in web-based application systems to facilitate staff compliance.

Developing such a system can admittedly be a daunting and time consuming undertaking.  Depending on internal capabilities, institutions may need to conduct staff training, add staff or use consulting services.  The consultants at Stevens Strategy have extensive experience developing institution-wide policy manuals for higher education clients with a proven methodology and we would be happy to be of service.  For more information, you can reach us at [email protected].

Stephen Lazarus, JD

Senior Consultant, Stevens Strategy