William & Mary's Policy Program, managed by the Office of Compliance & Equity, is an inclusive, flexible process for developing, finalizing, and disseminating important rules -- policies, procedures, or regulations -- governing university people, assets, and operations. The Program may also be used for significant modification (revisions) of important policies and procedures.
The Policy Program is used primarily for administrative rather than academic policies, which are developed by faculty entities.
The Program has three main stages:
Policies may be developed by the Office of Compliance & Equity in consultation with subject-matter experts, or by the university unit (office, department, school, etc.) with an interest, responsibility, or expertise in the policy issue with support and consultation from Office staff. Initial steps in policy development include
- considering the purpose and needfulness of the policy, to avoid creating an unnecessary policy and to help determine the scope and content of the policy
- deciding whether the intended purpose is best met by a policy, procedure, or regulation (there are additional requirements for the creation of regulations under state law; the Chief Compliance Officer is W&M's Regulatory Coordinator and coordinates regulatory development),
- assessing the potential impact of the policy, which will affect the way it should be developed and approved, and
- identifying interested parties.
Policies are structured using a standard format, designed to provide clarity as to who or what is subject to the policy, its purpose, and when and how it was approved (authority).
After an initial draft is developed, authors typically seek input from other subject-matter experts and interested or affected entities. Particularly important policies may be reviewed by the President's Cabinet (full group of VPs and others senior administrators including the University Counsel).
Based on the scope of the policy -- that is, which entities and people it applies to -- as well as its significance, the Office of Compliance & Equity and the policy drafters, with consultation as needed, decide on the appropriate university officer to act as policy approver. For certain policies, other rules (state law, university by-laws or resolutions, other policies) may require review or approval by a particular entity, such as the Board of Visitors. (The Board has ultimate authority over all university policies.) In general, policies may be amended or eliminated by the officer that approved the policy or by anyone to whom amendment authority has been delegated.
Draft policies should be reviewed by the approver prior to being posted for finalization and approval.
Policies typically are posted online on the Proposed Policies website, typically for at least 30 days. Notices are made in the W&M Digest and, when appropriate, with direct messages to other interested groups, to seek input. Comments are solicited through an online submission form.
When the notice-and-comment period is over, the comment form is removed and the Proposed Policies website updated to indicate that the policy is under review/being finalized.
All comments are reviewed by the Office of Compliance & Equity and the policy drafter(s). Revisions are made when deemed appropriate. Additional input and review may be sought from subject-matter experts, legal, and others involved in initial drafting.
After any revisions are finished, the drafters submit the policy in final form to the approving officer for approval. (See previous section on Policy Development for a discussion of factors to consider in selecting the appropriate approving entity.) The effective date is decided.
In some cases, particularly when a policy or policy revision is needed to satisfy a compliance requirement, a policy or policy amendment will be finalized and approved without campus notice and comment.
The final, approved policy is posted online, either in the policy library or on the appropriate university office website with a link from the policy library. Appropriate hyperlink and other website updates are made.
The final policy is announced either through the W&M Digest, blast email to affected groups, or other messaging.
Typically, a policy is made effective upon publication. A policy may have a delayed effective date or other implementation conditions.
Updated January 2016