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Definitions
A-Z Policy Index (the Index) | A publication by the university of all active University Policies and UOPs, organized by scheduled review date, category, and Responsible Official. |
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Policy Advisory Team (PAT) | A team comprised of representatives from the Office of General Counsel, Internal Audit, Safety and Compliance, Risk Management, and Human Resources that convenes to review and provide feedback on all submitted as well as any new or significantly revised policy or UOP drafts. The Policy Advisory Team also helps ensure that new or revised University Policies and UOPs follow an approved format and process, are current, align with existing governing documents, and are approved by the respective Responsible Official. |
Resource Website | A University web page or posted document that contains links to related University Policies, UOPs, University Guidelines, forms, additional resources, and other information related to a specific topic. Resource pages consist primarily of best practices designed to simplify/streamline compliance and do not create new job requirements unless approved in advance by Human Resource Services (HRS). |
Responsible Official (RO) | A senior institutional official, typically the President, the Provost, a Vice President, Vice Provost, or a Chief Officer, who has responsibility for the oversight of specific programs, activities, conduct, or endeavors. |
University Guideline | An interpretation or elaboration of a University Policy or UOP issued by the Responsible Official or another University administrator who has responsibilities for administering the program, activity or operation that is the subject of the Policy or UOP. University Guidelines are generally applied throughout the University or to major components of the University. Guidelines that are developed by an individual unit and applied only to that unit are not considered University Guidelines under this policy. |
University Operating Procedure (UOP) | A freestanding operational rule or set of steps that all persons engaged in the activities that are the subject of the UOP must uniformly follow. UOPs are generally applied throughout the University or to major components of the University. Procedures that are developed by an individual unit and applied only to that unit are not considered a UOP under this policy. |
University Policy | A University Policy establishes principles and standards governing the conduct of ¶¶Òõ̽̽ faculty, staff, and students in their capacity as members of the ¶¶Òõ̽̽ community. Where specified, a University Policy may also apply to campus visitors, affiliates, vendors, or other members of the University community. A University Policy is defined by the following criteria: It applies generally throughout the University or major components of the University; It facilitates compliance with internal or external laws, regulations, standards, or requirements; and It mandates or constrains action, and it states the consequences for non-compliance. While a University Policy may contain procedures that set forth the specific steps or means by which the policy is carried out, these procedures are not the same as a UOP. Procedures contained within a policy exist to ensure consistent and efficient application of the Policy. |
General
The University follows a uniform policy process.
- Identify need.
- Develop and approve.
- Publish.
- Disseminate and train, attest and/or certify.
- Review and revise.
- Maintain.
University Policies, UOPs, and Guidelines that are housed on the Institutional Policy Website will always supersede unit, division, department, school, or college level policies, procedures, and guidelines. Guidelines are generally not posted on the institutional policy website; however, for those Guidelines that have University-wide impact, they may be posted upon request, with Responsible Official sponsorship, and Policy Advisory Team approval.
Responsibilities
Website:
The Office of Compliance and Privacy Services is responsible for the management of ¶¶Òõ̽̽’s institutional policy website and oversees the policy process.
Development & Updates:
Responsible Officials are independently obligated to ensure that Policies and UOPs are updated according to ¶¶Òõ̽̽’s policy review calendar or as otherwise necessary to remain current. The creation, review, and revision of University Guidelines and Resources Websites is under the discretion of the Responsible Official or another University administrator responsible for the activity. It is the Responsible Official’s responsibility to review resource pages and guidelines to ensure that they are current and up to date.
In a timely manner Responsible Officials are responsible to collect, review and either approve or deny comments received during the campus comment period and to submit a final draft to the Office of Compliance and Privacy Services. Under extenuating circumstances, Responsible Officials may request an extension by sending an email to policy@uvm.edu.
Communication, Dissemination & Training:
Responsible Officials are responsible to communicate and disseminate the Policy/UOP to affected parties, to ensure adequate training is provided to relevant individuals, and to retain proof of training, attestation and/or certification documentation according to applicable regulatory requirements and/or any University Policies/UOPs. The best and most efficient and effective method of dissemination, communication, and training is at the discretion of the Responsible Official. Responsible Officials may engage other individuals or units to perform or assist with these duties; however, the Responsible Official maintains sole responsibility for the requirements under this section.
Review Cycle
All University Policies and UOPs are formally reviewed within three academic years of the date of the initial approval, or the date most recently reviewed or revised unless otherwise specified in the Policy or UOP. Review of University Guidelines and Resources Websites is done at the discretion of the Responsible Official for the unit/division that is responsible for the activity. The review schedule is maintained by the Office of Compliance and Privacy Services and is listed in the A-Z Policy Index located on the University’s institutional policy website.
The review cycle is based on the academic year (June 1 – May 31). Responsible Officials are required to oversee the initial development, as well periodic review/revision, of University Policies and UOPs relating to their business units and areas of responsibility. Responsible Officials should contact the Office of General Counsel in advance with any questions regarding general legal obligations and should contact the Office of Compliance and Privacy Services for questions related specific compliance requirements, policy process, or policy/UOP format.
Procedures
New/Substantially Edited Policy/UOP Process
In most cases, prior to developing a new or substantially editing a University Policy or UOP, the Responsible Official, another responsible University administrator, or a member of the Policy Advisory Team fills out a . The Policy Advisory Team may waive the form requirement; however, Responsible Officials must request this by sending an email to policy@uvm.edu stating the reasons why the form is not necessary. If the individual submitting the form is anyone other than the Responsible Official, that person is responsible to provide a copy of the submitted form to the Responsible Official.
The Policy Advisory Team, in consultation with the Responsible Official, reviews submitted forms and will either approve, deny, or request modification to the request and will communicate their decision to the Responsible Official timely.
Revisions to Existing Policies/UOPs Process:
There are three levels of revisions:
- Level 1/Housekeeping Revisions are non-substantive or technical corrections or clarifications. Examples include grammatical edits, formatting, adding reference links, changes to contact information, or clarification of existing procedural processes. Housekeeping revisions may be made administratively under the discretion of the Director of Compliance Services.
- Level 2/Minor Revisions may include some operational changes but do not impose new responsibilities or do not substantially change existing responsibilities for affected units or individuals. The changes also do not materially affect individuals, departments, or units. Examples include minor procedural changes, changes in workflow, and updating process mechanisms (i.e., paper form to electronic submission). Minor revisions may be made administratively by the Director of Compliance Services, in consultation with the Responsible Official and the Office of General Counsel.
- Level 3/Substantial Revisions impose a change in scope or obligations set by the policy, set new requirements, have a substantive operational impact on departments/units, or hold individuals or entities to new or different standards or obligations. Examples include new accountability standards, additional procedural requirements, or reassignment of responsibilities to other units, individuals, or responsible officials. Substantial edits follow the same approval process as new Policies/UOPs.
The level of revision is determined by the Director of Compliance Services in consultation with the Responsible Official and the Office of General Counsel.
As University Policies/UOPs are superseded by new versions or revoked by responsible officials, they will be retired, and copies archived by the Office of Compliance and Privacy Services. For both housekeeping and minor revisions, the Office of Compliance and Privacy Services shall maintain a record of the nature and extent of the revisions and the date revised.
Adoption of Interim University Policies:
Under extenuating circumstances, Interim University Policies may be issued by a Responsible Official. Such circumstances are limited to: (i) external compliance deadlines; (ii) developments that will, or could, significantly affect the safety or welfare of members of the campus community; (iii) an identified need to facilitate orderly and efficient campus operations; (iv) to allow for impact bargaining as it relates to represented employees; or (v) other instances authorized by the Policy Advisory Team. In all cases, the Responsible Official must seek Policy Advisory Team approval to issue an interim policy by means of a request sent in writing to policy@uvm.edu.
Under most cases, an Interim Policy/UOP will not remain in effect for more than 180 days from the effective date of their issuance; thus, the Responsible Official, in consultation with the Office of General Counsel and, as it relates to collective bargaining unit members, Labor and Employee Relations, should initiate the steps described above for adoption of a final Policy promptly.
Interim University Policies, clearly designated as such, will be posted on the Institutional Policies website.
A-Z Policy Index
A current list of University Policies, UOPs, and University Guidelines is maintained on the Institutional Policies website. The Index can be found on the Institutional Policies website. The Index is updated on an on-going basis as University Policies, UOPs, and University Guidelines are developed, modified, or retired.
Is there training available?
Training will be provided on an as-needed basis as determined by the Approval Authority or the Responsible Official.