I. Purpose
A. This Interim Procedure on Development of Policies and Procedures (“Development Procedure”) is established to implement the Anne Arundel Community College (“College”) Policy on Development of Policies and Procedures (“Development Policy”).
B. This Development Procedure provides direction on the process for creating, revising, discontinuing, reviewing, approving, implementing, communicating, and publishing Policies and Procedures.
II. Scope and Applicability
A. This Development Procedure applies to all members of the College community, including faculty, staff, students, trustees, and guests on College premises.
B. With the exception of the Shared Governance Policy and Procedures, this Development Procedure applies to all Policies, Procedures, and Guidelines created, revised, or discontinued after the Effective Date of these Procedures.
C. This Development Procedure does not apply to Internal Guidance. To the extent possible, departmental or program specific rules should not be referred to as a policy or procedures to distinguish such rules from Policies that are approved by the Board and Procedures that are approved by the President and apply College-wide.
D. To the extent that the College Manual conflicts with this Development Procedure, this Development Procedure supersedes the College Manual.
III. Definitions
A. All capitalized terms in this Development Procedure have the meanings provided in the Policy.
B. All other capitalized terms in this Development Procedure have the following meanings:
1. Business Days is any day which is not a Saturday or Sunday or day that the College is closed, such as holidays, spring break, winter break, or other day that the College announces that it is closed.
2. CDEIO is the Chief Diversity, Equity, and Inclusion Officer or designee.
3. Co-Chairs are the members of the Review Committee selected to lead the Review Committee and assign members to serve on Review Panels.
4. Drafter is a member of the GC’s office or the CCFPO assigned by PVP to assist the Policy Administrator in drafting and reviewing a particular Policy and/or Procedure.
5. Drafting Guidelines are guidance on how to draft or revise Policies and/or Procedures.
6. Guidelines are a set of general rules, principles, recommendations or instructions that apply to the College community.
7. Interim Procedure is a Procedure that is approved by the Policy Owner in accordance with this Development Procedure on an interim basis in situations where a Policy Action must be taken within a time period that is too short to permit the completion of the Review and Approval processes.
8. Policy Action Request is a form used to seek a Policy Action.
9. Review Committee is a standing committee of fifteen (15) members—five (5) representatives of TFO, five (5) representatives of ASO, and five (5) representatives of PSSO, as determined by each Constituency Group—that is a pool from which the Review Panel is drawn.
10. Review Panel consists of three (3) members—one (1) representative from TFO, one (1) representative from ASO, and one (1) representative from PSSO—selected from the members of the Review Committee to solicit feedback from their respective constituency groups and work with the Policy Administrator and Drafter to incorporate the feedback received.
11. Subject Matter Expert is an employee who can provide knowledge on the specific subject, pedagogy, business area, business process, or technical issues as may arise within the scope of the Policy or Procedures under consideration based on the employee’s position at the College, including particular knowledge based on the employee’s job description, job duties, other experience, department work, functions, processes, use of specific equipment, software, and/or materials, or understanding of historical information.
IV. Request
A. To initiate a Policy Action, the requestor must submit a Policy Action Request electronically and must include the reason(s) for the requested Policy Action and a summary of the new Policy and/or Procedure to be created or the proposed changes.
1. The requestor can submit a draft, sample policies or procedures, or a description, outline, or list of proposed provisions with Policy Action Request.
2. If the Policy Action Request is missing information or needs clarification, the CCFPO or designee may consult with the individual who submitted the Policy Action Request and revise the Policy Action Request, as needed.
B. PVP will review the Policy Action Request.
1. If PVP recommends proceeding with the proposed Policy Action that relates to a Policy, the President or designee will submit the Policy Action Request to the Board Committee.
2. If the proposed Policy Action relates solely to a Procedure, PVP shall review and determine whether to approve the Policy Action for drafting.
3. PVP will prioritize the order in which Policies and Procedures are to be drafted.
4. If not already identified, PVP will assign a Policy Category for the Policy and/or Procedure, selected from the following:
a. Academic Affairs;
b. Administration, Business, and Fiscal Affairs;
c. General;
d. Human Resources;
e. Information Technology;
f. Faculty Affairs; and
g. Student Affairs.
5. When a Policy and/or Procedure is ready to be drafted, PVP will appoint:
a. A Policy Owner, if not previously identified;
b. A Policy Administrator, if not previously identified; and
c. A Drafter.
6. The Policy Administrator and Drafter will serve as the Drafting Committee.
7. The Special Assistant or designee will maintain a list on the College’s Intranet of Policies and Procedures that are being drafted, the Policies and Procedures under review, the due dates for review, the Policy Administrator assigned to each Policy and Procedure on the list, and once appointed, the members of the Review Panel.
V. Drafting
A. The College recognizes that standardizing all Policies and Procedures pursuant to the Development Policy and Procedure will occur over time and that as Policies and Procedures are revised, the College will reformat them to follow the Policy or Procedures Template (“Templates”).
B. The Policy Administrator will work with the Drafter to create or revise the Policy and/or Procedures, using the Templates.
C. If the College Manual covers the same subject matter as the Policy and/or Procedure under development, the Policy Administrator and the Drafter will draft revisions to the College Manual, if needed, to avoid inconsistencies.
D. During the drafting period, the Policy Administrator will complete an Implementation Plan to determine how to comply with applicable laws, regulations, and accreditation standards; whether other Policies or Procedures may be impacted; whether changes will need to be made to business processes, technology, catalog provisions, College websites, marketing materials, employee training materials, forms, guidelines, Internal Guidance, or any other materials that may be impacted; how the Policy and/or Procedure should be communicated to the College community or specific groups within the College community; and a proposed Effective Date for when the Policy and/or Procedures will be published on the College’s website and take effect.
E. During the drafting process, the Policy Administrator or Drafter may consult with Subject Matter Experts, including Constituency Group leaders, on the Policy, Procedure, and/or the Implementation Plan, prior to finalizing the draft for review.
F. The Policy Administrator or Drafter will submit the draft of the Policy, Procedure, College Manual, and/or Implementation Plan to the GC to review with the Policy Owner.
1. The Policy Owner will provide feedback to the GC or designee who will work to incorporate any suggested revisions.
2. After any changes are made, the Policy Owner will approve the Policy and/or Procedure for review by the College community.
VI. Review
A. Except for Interim Policies and Procedures, TFO, ASO, and PSSO will be invited to provide feedback on every Policy and Procedure prior to approval through the Review Panel.
1. If a Policy and/or Procedure may have a significant effect on students, such as grading, codes of student conduct, academic misconduct, student grievances, curriculum development, courses or programs that should be discontinued, and student fees, SGA will be invited to appoint a student(s) to review a draft of the Policy and/or Procedures and provide feedback to the CCFPO or designee.
2. The CDEIO will be invited to review every Policy and Procedure from an equity lens and will provide feedback to the CCFPO or designee.
B. Review Committee
1. Each member of the Review Committee will serve a one (1) year term.
2. If a Review Committee member vacates the position in the middle of a term, the Constituency Group will select another member of the Constituency Group to serve the remainder of the term for the member who vacated the position.
3. Review Committee members may serve three (3) consecutive terms, after which time, the member must not serve on the Review Committee for at least one (1) year.
4. At the beginning of the academic year, the Review Committee members will select two (2) Co-Chairs, from among the current members who must be from two (2) different Constituency Groups.
C. Review Panel
1. When a Policy and/or Procedure is ready for review, the Co-Chairs will select one (1) member of the Review Committee from each Constituency Group to create a Review Panel, based on interest in the subject, member schedules, and an equitable distribution of the number of Policies and Procedures assigned to each member.
2. The members of the Review Panel are responsible for representing their Constituency Group’s position on a particular language in the Policy and/or Procedure based on the feedback received.
3. The CCFPO or designee will submit the draft Policy and/or Procedure to TFO, ASO, PSSO, and the CDEIO for review. If appropriate, the CCFPO or designee will also submit the draft Policy and/or Procedure to SGA for review.
4. Members of Constituency Groups will be given thirty (30) calendar days to provide comments or suggest changes. The CCFPO may determine to provide additional review time if the College is closed during the review period.
5. The Review Panel members may seek to discuss the draft Policy and/or Procedure at a Constituency Group meeting(s) or with individuals in their Constituency Groups to clarify the feedback and the positions of the Constituency Group as a whole.
6. The Review Panel will review the feedback received from the Constituency Groups and determine which comments and suggested changes to propose as follows:
a. The Review Panel will limit its feedback to proposed edits to the language of the Policy and/or Procedures or constructive comments meant to convey specific conceptual concerns about the draft.
b. The Review Panel will draft revisions or provide comments by creating a markup of the draft Policy and/or Procedure, using technology that tracks changes and permits comments.
7. The Review Panel will provide the markup to the CCFPO or designee within five (5) Business Days of the deadline for Constituency Group review, unless a shorter time frame is requested by the CCFPO or designee.
a. The CDEIO will provide a markup of the draft Policy and/or Procedure to the CCFPO or designee by the deadline provided for the Review Panel.
b. If the SGA was invited to provide student feedback, the SGA president will provide the feedback to the CCFPO or designee by the deadline provided for the Review Panel.
8. Upon receipt, the CCFPO or designee will submit the feedback form the Constituency Groups, CDEIO, and SGA, if applicable, to the Policy Administrator.
9. The Policy Administrator will convene meetings in the format determined by the Policy Administrator, such as through electronic means, with the Drafter and the Review Panel to review the feedback and determine whether to accept the proposed revisions or comments, make revisions, or reject the proposed revisions or comments. The Policy Administrator may invite Subject Matter Experts to attend the meetings.
10. If necessary, the Policy Administrator will make changes to the Implementation Plan.
D. PVP Review
1. Once the feedback is incorporated, the Policy Administrator will provide the revised draft to the GC to review with PVP.
2. PVP will provide feedback to the GC or designee who will work to incorporate any suggested revisions.
3. After any changes are made, PVP will approve the Procedure in accordance with the Procedure Approval Section below or may delay approval until the Board approves any accompanying Policy.
4. If the Policy Action relates to a Policy, PVP will approve the Policy for submission to the Board Committee.
E. Board Committee Review
1. The Special Assistant or designee will follow the Development Policy for submission of the Approval Form and draft of the Policy to the Board Committee.
2. If substantive revisions are made at any stage of the review process, at the discretion of the President, the President may request additional feedback in the manner determined by the President.
VII. Approval
A. Policy Approval
1. The Special Assistant or designee will follow the Development Policy for submission of the Approval Form and draft of the Policy to the Board.
2. After the Board votes on a Policy, the Special Assistant or designee will complete the Approval Form.
3. If the Board approves the Policy, the Special Assistant or designee will:
a. Submit a clean copy of the Policy to the Policy Administrator for implementation or discontinuation;
b. Submit the Policy to be published on the College’s website on or before the Effective Date;
c. Archive any prior version of the Policy;
d. Maintain the Approval Form;
e. Calendar the next required review cycle, which shall be no more than five (5) years from the Effective Date.
4. If the Board declines the Policy, the Special Assistant or designee will:
a. Notify the Policy Administrator to determine if further action is needed; and
b. Maintain the Approval Form.
5. Upon receipt, the Policy Administrator will begin implementation and communication in accordance with the Implementation Plan.
B. Procedure Approval
1. If the Policy Action relates solely to a Procedure, PVP may reach a consensus as to whether to approve the Procedures. If PVP cannot reach a consensus, the President will decide whether to approve.
2. If the Policy Action relates to both a Policy and related Procedures, the President may wait until after the Policy is approved by the Board to approve the Procedures to ensure consistency.
3. After PVP considers the Procedure, the Special Assistant or designee will complete the Approval Form.
4. If approved, the Special Assistant or designee will:
a. Submit the approved Procedures to the Policy Administrator for implementation or discontinuation;
b. Submit the Procedure to be published on the College’s website on or before the Effective Date;
c. Archive any prior version of the Procedures;
d. Maintain the Approval Form.
e. Calendar the next required review cycle, which shall be no more than five (5) years from the Effective Date.
5. If declined, the Special Assistant or designee will:
a. Notify the Policy Administrator to determine if further action is needed; and
b. Maintain the Approval Form.
6. Upon receipt, the Policy Administrator will begin implementation and communication in accordance with the Implementation Plan.
C. After a Policy and/or Procedure is approved, the Policy Administrator, in consultation with the Drafter, will draft an explanation as to the reason(s) changes proposed during the Review process were not incorporated to the Policy Owner for review. The Policy Owner will approve the explanation, which will be posted on the College’s Intranet.
VII. Interim Procedures
A. The President delegates authority to the Policy Owner to approve an Interim Procedure in the following circumstances:
1. The need for immediate compliance with applicable law, regulations, or notice from a regulatory agency, accreditor or other oversight entity;
2. Identification of a potential adverse impact to a time-sensitive College strategic project or initiative or College operations;
3. Identification of a gap or omission or conflict with another Policy that creates immediate risk or vulnerability for the College; and/or
4. Identification of an unanticipated significant negative impact on the College if a Procedure is not adopted, changed, or discontinued quickly.
B. An Interim Procedure will remain in force until adopted, with or without revisions, through the Review and Approval process described in above or for up to twelve (12) months from the date of issuance, whichever occurs first.
C. If an Interim Procedure is established by the Policy Owner, the Policy Owner will confirm the Effective Date, and the Special Assistant or designee will update the Procedure on the College’s website on or before the Effective Date and maintain the Procedure in the same manner as other Procedures and will title the Procedure as “Interim.”
IX. Guidelines
A. The President authorizes each of the Vice Presidents to issue Guidelines that are within the purview of the Vice President but apply College-wide.
B. The Vice President must consult with the GC’s office before publishing Guidelines.
C. Once approved by a Vice President, the Special Assistant or designee submit the Guidelines to be published on the College’s website on or before the Effective Date.
D. A Vice President may make updates to Guidelines within the purview of the Vice President by notifying the Special Assistant or designee of the proposed changes.
Policy Title: Interim Procedure on Development of Policies and Procedures
Policy Category: Administration, Business, and Fiscal Affairs
Policy Owner: President
Policy Administrator: Chief Compliance and Fair Practices Officer
Contact Information: 410-777-1239; complianceofficer@aprender-a-bailar.com
Approval Date: June 12, 2023
Effective Date: August 16, 2023
History: Approved Nov. 9, 2021
Applies to: All members of the College community
Related Policies: Policy on Development of Policies and Procedures
Related Procedures: N/A
Forms/Guidelines:
Relevant Laws: N/A