Policy on Policies

Policy Statement

The President of the College has general control and supervision over all matters pertaining to the College and its activities, subject to the advice and approval of the Board of Trustees. Pursuant to that authority, the President approves all College Policies or delegates to College officers the ability to develop policies and procedures for their areas of responsibility, consistent with College Policies. 

Reason for the Policy

This Policy establishes a development, approval, review, promulgation, amendment, and withdrawal process for all College Policies to assure consistency and compliance with law. By implementing this uniform process, the College seeks to enhance operational efficiencies, best practices, effective decision-making, and compliance with laws and regulations across the College. This policy also helps ensure that policies are easily accessible and understandable, widely disseminated, consistent, and reviewed and approved in an appropriate way. 

Definitions

  • College PolicyA directive that is meets one or more of the following criteria:
    • Has broad application throughout the College, helps achieve compliance with applicable state and federal laws and regulations, or manages institutional risks.
    • Mandates actions or constraints, and contains specific procedures for compliance with the policy;
    • Is required by consent decree, resolution agreement, settlement, or other external legal authority;
    • Is officially sanctioned through the College Policy approval process; and
    • Is presented in the format required under this Policy.

Policies established and administered by the Board of Trustees are not College Policies. Note there are some policies that predate this policy and so, as yet, have not been through the entire process outlined herein. They remain official college policies and, in time, are expected to complete this process.

  • Responsible Officerthe Vice President (or, in the case of the Office of the Arts, the Executive Director and, in the case of Student Affairs, the Dean of Students) with principal responsibility for the substantive area covered by a particular College Policy and who is considered the “owner” of the Policy for purposes of creation, implementation and timely updating of the College Policy. 
  • College Policy Review Committee or “Committee”—the Vice President for Administration and Finance, the Vice President for Academic Affairs, and the Dean of Students.  The Committee is advised and staffed by Vice President and General Counsel.  Other senior officers, staff and faculty may be consulted by the Committee and/or invited to join its meetings to discuss specific policy issues.  The Committee is advisory to the President.

Statements of Elaboration of the Policy

I. College Policies and Procedures

A. Other Emerson policies that govern the activities of a specific division, department or group, such as the Faculty Handbook, are not governed by this Policy.  Those policies are drafted, revised and adopted in accordance with their own procedures and when appropriate in a shared governance model. Those policies may not conflict with or override a College Policy unless first approved pursuant to the exceptions process in III (I).
B. College procedures are descriptions of the appropriate steps to take in complying with a College Policy.

II. Establishing an Interim Policy

When a policy is needed within a time period that does not allow for complete drafting and review of the policy document as outlined in this document, the Responsible Officer may request the Committee to allow promulgation of that policy on an interim basis. The Committee must give explicit permission to issue a policy as interim. 

Interim policies are effective for six months to a maximum of twelve months. Extensions beyond twelve months must be approved by the Committee. To derive the benefits of a standard policy document and the full review cycle, the Responsible Officer must complete the process outlined in this document, preferably, within one year of the promulgation of the interim policy.

III. Development of College Policies and Procedures

A. College policies will be:

a. Presented in a common format
b. Formally approved by the Committee
c. Maintained centrally and accessible to all
d. Linked electronically to procedures for implementation of the policy
e. Kept current within the framework of a system an organized system of change control

B. If a Responsible Officer determines that an existing or proposed policy may have College-wide application, he or she submits the policy proposal to the College Policy Review Committee for review.

C. All College Policies must be in a format similar to the sample policy template attached hereto as Appendix A.

D. The Committee reviews the policy proposal and takes one of three actions: it appoints the Responsible Officer to draft or revise the policy as a College Policy, it authorizes the formation of an ad hoc policy-drafting committee to do so, or it determines that the proposed policy or revision does not fall under this policy.

E. When a proposed College Policy has been drafted or revised as specified, the document is submitted to the Committee for review and approval. The Committee may determine that the proposed policy should be reviewed by representatives of particular College constituencies; if so, the Committee will arrange for such review.

F. If the Committee approves the proposed College Policy, it is forwarded to the President and the President’s Council for review and approval. The President, in consultation with the Vice President and General Counsel, determines if the proposed College Policy should receive the approval of the Board of Trustees.  Following approval by the President and/or the Board of Trustees, as the case may be, the College Policy is disseminated to the Emerson community as specified by the Committee, in consultation with the Vice President for Communication and Marketing.

G. The Responsible Officer should ensure that College Policies are reviewed, updated and/or revised as needed in accordance with applicable laws and regulations, but at a minimum every three years.

H. Changes to Policies in substance or principle must be approved by the Policy Committee based on the Responsible Officer’s submission of a revised Policy, including a new impact statement, to the Committee. On an as-needed-basis, the Responsible Officer will request of the Committee routine changes (such as new contact names, position titles and email or Web addresses) to an existing policy document.

I. The Responsible Officer, may grant Policy exceptions for good cause shown, such as unusual facts or circumstances that make adherence to the College Policy impossible or impracticable. The Responsible Office will grant no exception that may violate federal, state or local laws or regulations, including governmental rules relating to grants and contracts. In evaluating a request for an exception to a College Policy, the Responsible Officer  will meet the following standards:

  • If there is any question whether the exception may implicate federal, state or local laws or regulations, the Vice President and General Counsel must be consulted before any exception is granted.
  • An exception is ordinarily limited to the particular facts and circumstances giving rise to the request. Should the facts and circumstances indicate an issue that may recur or a broader issue, the Responsible Officer should consider submitting a request to the Committee to revise the College Policy to avoid the need for an exception on a similar issue in the future.

J. Violations of College Policy may result in disciplinary action up to and including termination of employment or expulsion from the College and, in some cases, may subject the violator to civil or criminal action. 

The College has established a hotline. The hotline provides an easy way to discreetly and confidentially report activities that may involve criminal, unethical or otherwise inappropriate violations of College Policies. The hotline is not a substitute for established channels of responsibility, but it does provide opportunities for reporting behavior when those mechanisms are not suitable. The hotline is operated 24 hours a day, 365 days a year and can be accessed by calling Ethics Point at 855-659-7662 or making a report online via https://secure.ethicspoint.com/domain/media/en/gui/34656/index.html.

IV. Withdrawing a Policy

In special circumstances, a Responsible Officer may deem it appropriate to withdraw an existing College Policy or consolidate it with another College Policy. The Responsible Office must inform the Committee of this intent and issue an announcement of a withdrawn policy in consultation with the Vice President of Communications and Marketing. 

Key Office to Contact Regarding this Policy and its Implementation

The Vice President and General Counsel of Emerson College is responsible for the oversight and implementation of this policy.

The Responsible Officer for this policy is the President of the College. Questions relating to the implementation of this policy should be directed to the General Counsel, or the appropriate Vice Presidents for aspects of implementation for which they are responsible.

Date of Initial Policy: April 17, 2014


Appendix A

Emerson College Policy Template

The following template should be used for College Policies:

Emerson College Policy No. _____              

TITLE OF POLICY 

  • Policy Statement [General Statement of Policy, including whom it covers (all employees, faculty, staff, students, others)]
  • Reason for the Policy
  • Definitions [Defined terms in the policy, if applicable]
  • Statements of Elaboration of Policy, if any [Insert subsections with headings and details concerning the policy, including specific issues or situations, responsibilities and mechanisms for compliance]
  • Cross References to Related Policies
  • Responsible Officer [Provide the Title of the Responsible Officer for the Policy]
  • Key Offices to Contact Regarding the Policy and its Implementation
  • Links to Procedures or Forms
  • Date of Initial Policy
  • Date(s) of Any Revisions
  • Signature Line for the President