I. Purpose
A. These Procedures on Development of Policies and Procedures (“Development Procedures”) are established to implement the Anne Arundel Community College (“College”) Policy on Development of Policies and Procedures (“Development Policy”).
B. These Development Procedures provide direction on the process for creating, revising, discontinuing, reviewing, approving, implementing, communicating, and publishing Policies and Procedures.
II. Scope and Applicability
A. These Development Procedures apply to all members of the College community, including faculty, staff, students, trustees, and guests on College premises.
B. These Development Procedures apply to all Policies and Procedures created, revised, or discontinued after the Effective Date of these Procedures.
C. These Development Procedures do 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 these Development Procedures, these Development Procedures supersede the College Manual.
III. Definitions
A. All capitalized terms in these Development Procedures have the meanings provided in the Policy.
B. All other capitalized terms in these Development Procedures 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. Drafting Guidelines are guidance on how to draft or revise Policies and/or Procedures.
3. Interim Procedure is a Procedure that is approved by the President in accordance with these Development Procedures 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.
4. Request Form is a document used to seek a Policy Action.
5. Review Committee is a standing committee of representatives of the TFO, ASO, and PSSO that is responsible for reviewing Policies and Procedures and providing an opportunity for community feedback.
6. Review Packet includes the Approval Form, which is used to route a Policy and/or Procedures for review; a copy of the original Policy and/or Procedures; a markup showing the revisions to the Policy and/or Procedures or draft of the new Policy and/or Procedures; a markup of the applicable portions of the College Manual, if any.
7. 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. Policy Request
A. To initiate a Policy Action, the requestor must submit a Request Form electronically and must include the reason(s) for the requested Policy Action and a summary of the new Policy and/or Procedures to be created or the proposed changes.
B. If the Request Form is missing information or needs clarification, the CCFPO or designee may consult with the individual who submitted the Request Form and revise the Request Form, as needed.
C. Once finalized, the Special Assistant or designee will submit the Request Form to the President.
1. If the President, in consultation with PVP, recommends proceeding with the proposed Policy Action that relates to a Policy, the President or designee will submit the Request Form to the Board Committee.
2. If the proposed Policy Action relates solely to Procedures, the President, in consultation with PVP, shall review and determine whether to approve the Policy Action for drafting.
D. If the proposed Policy Action is approved for drafting by the Board or the President, the Special Assistant or designee will place the proposed Policy Action on the list based on the Board’s prioritization for Policies and the President’s prioritization for Procedures.
E. If not already identified, the President, in consultation with PVP, will assign a Policy Category for the Policy and/or Procedures, selected from the following:
1. Academic Affairs;
2. Administration, Business, and Fiscal Affairs;
3. General;
4. Human Resources;
5. Information Technology;
6. Faculty Affairs; and
7. Student Affairs.
V. Appointment of Policy Owner, Policy Administrator, and Drafting Committee
A. The Special Assistant or designee will notify the President when a Policy Action is next on the list for drafting.
B. Upon notification, the President, in consultation with the Vice Presidents, will appoint:
1. A Policy Owner, if not previously identified;
2. A Policy Administrator, if not previously identified;
3. The Drafting Committee, including:
a. The Policy Administrator;
b. Employees (typically between 3-5 total) who are Subject Matter Experts related to the Policy and/or Procedures at issue; and
c. Either the GC or CCFPO to support the Drafting Committee with drafting.
C. If Constituency Group representation is appropriate, the President will consult with the president of a Constituency Group to make appointments under this Section in accordance with the Constituency Group’s Charter or protocols. If the Policy or Procedure is within the Academic Affairs or Faculty Affairs Category, at least one (1) faculty representative(s) will be invited to serve on the Drafting Committee.
D. Upon appointment, the Special Assistant or designee will send the Request Form to the Drafting Committee.
E. The Special Assistant or designee will maintain a list of current Policies and Procedures submitted for drafting, the members of each Drafting Committee, and the Policy Category, which will be posted online or otherwise provided to Constituency Group presidents.
VI. Drafting
A. The College recognizes that standardizing all Policies and Procedures pursuant to the Development Policy and Procedures will occur over time and that as Policies and Procedures are revised, the College will reformat them to follow the Policy or Procedures Template.
B. The Policy Administrator will convene the Drafting Committee to determine roles and responsibilities for drafting, revising, or considering discontinuation of the Policy and/or Procedures and reviewing the College Manual to determine if the subject matter of the Policy and/or Procedures is also covered in the Manual.
1. If the College Manual covers the same subject matter, the Drafting Committee will recommend removal of such content from the Manual or draft revisions, if needed, to avoid inconsistencies.
2. The recommendations for the College Manual will be included with the Review Packet.
C. The Drafting Committee will use the Policy and Procedure Templates and Drafting Guidelines and will draft revisions by creating a markup, using technology that tracks changes and permits comments.
D. Feedback from Other Community Members
1. During the drafting process, members of the Drafting Committee may seek feedback from other employees who have subject matter expertise on a particular portion of the Policy and Procedures where it would be beneficial to obtain their feedback or to review from an equity lens, as needed, prior to finalizing the draft for review.
2. If appropriate, the Drafting Committee will request that the Student Government Association appoint a student(s) to review a draft of the Policy and/or Procedures and provide feedback on any Policy and/or Procedures that 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.
3. If needed, in the discretion of the Policy Administrator, the Drafting Committee may consult with the GC.
E. Implementation Plan
1. During the drafting period, the Policy Administrator will complete the Implementation Plan Form, which will include a review of the following:
a. Applicable laws, regulations, and accreditation standards;
b. Other Policies, Procedures, and College Manual provisions that may be impacted;
c. Business processes;
d. Technology;
e. Catalog provisions;
f. College websites;
g. Marketing materials;
h. Employee training materials;
i. Forms/Guidelines;
j. Internal Guidance; and
k. Any other materials that may be impacted.
2. The Policy Administrator will develop a communication plan as part of the Implementation Plan Form, including:
a. Identifying which groups within the College community need to know about the Policy and/or Procedures;
b. Determining the mechanism(s) (g., community wide email, distributing through supervisors, meetings with specific departments, etc.) that will be used to communicate the Policy and/or Procedures to the community groups identified;
c. Developing a plan for training regarding the Policy, Procedures and/or subject matter;
d. Preparing a timeline for implementation, communication, and training; and
e. Proposing an Effective Date for when the Policy and/or Procedures will be published on the College’s website and take effect.
3. The Policy Administrator may consult with other employees, as needed, to complete the Implementation Plan Form.
4. The Policy Administrator will submit the Implementation Plan to the Drafting Committee for review and will incorporate any feedback received.
F. The Policy Administrator will submit the Review Packet and the Implementation Plan to the GC for review with the Policy Owner, and once finalized, the GC will submit the Review Packet to the Special Assistant or designee.
VII. Review Committee
A. The Review Committee shall include fifteen (15) members, five (5) from each Constituency Group, as determined by each Constituency Group.
B. The term for the members will be staggered for continuity of the Review Committee.
1. When these Procedures are established, each Constituency Group will select two members of the Constituency Group to serve a one (1) year term and three members of the Constituency Group to serve a two (2) year term on the Review Committee.
2. Thereafter, all Review Committee members shall be appointed for two (2) year terms.
C. 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.
D. Review Committee members may serve two (2) consecutive terms, after which time, the member must not serve on the Review Committee for at least two (2) years.
E. The Review Committee members will select two (2) Review Committee Co-Chairs, from among the current members.
1. The Co-Chairs must be from two (2) different Constituency Groups.
2. Each Co-Chair will serve a two (2) year term.
3. The term for the Co-Chairs will be staggered for continuity of the Review Committee.
a. In the initial year of this Development Procedure, the Review Committee will select two (2) Co-Chairs, one of which will serve a one-year term to be determined by a majority of the Review Committee members.
b. Thereafter, the Review Committee will select one (1) Co-Chair each year.
VIII. Review
A. All Constituency Groups will be invited to provide feedback on every Policy and Procedure prior to approval, using the following process.
B. Review Panel
1. Upon receipt of the Review Packet, the Special Assistant or designee will provide the Review Packet to the Review Committee Co-Chairs.
2. The Review Committee 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.
3. The Special Assistant will arrange for a meeting with the Review Panel, the CCFPO, the Policy Owner and/or the Policy Administrator. The GC may attend, as needed.
4. The members of the Review Panel are responsible for soliciting feedback on the Review Packet from their respective Constituency Groups as part of their review process, including:
a. Disseminating the Review Packet to their respective Constituency Groups;
b. Providing at least ten (10) Business Days for the Consistency Group to provide comments or suggest changes to the Review Packet;
c. Providing an efficient means for the members of the Constituency Group to provide comments or suggested changes to the Review Packet to their respective Review Panel members; and
d. In the discretion of the Review Panel members, discussing the Review Packet with Constituency Group members or at Constituency Group meetings.
5. 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 Review Packet.
b. If the Review Panel does not agree on which edits and comments to propose, the Review Panel can convene the entire Review Committee to discuss and determine which edits and comments to propose.
c. The Review Panel will draft revisions or provide comments by creating a markup of the Review Packet, using technology that tracks changes and permits comments.
6. The Review Panel will provide the markup of the Review Packet to the CCFPO or designee within twenty (20) Business Days of receipt of the Review Packet, unless a shorter time frame is requested by the CCFPO or designee.
7. In situations where expedited review is needed for good cause, the CCFPO or designee may request a shorter review period and will notify the Review Committee Co-Chairs of the time frame.
8. When the review is complete, the Review Panel will submit the markup of the Review Packet to the Special Assistant or designee.
C. Drafting Committee Review
1. Upon receipt, the Special Assistant or designee will provide the markup of the Review Packet to the Drafting Committee.
2. The Drafting Committee will review the feedback and determine whether to accept the proposed revisions or comments, make revisions, or reject the proposed revisions or comments.
3. If necessary, the Policy Administrator will make changes to the Implementation Plan.
4. Once the Review Panel’s feedback is incorporated, the Policy Administrator will provide the Review Packet to the Special Assistant or designee.
D. Legal Review
1. The Special Assistant or designee will provide the Review Packet to the GC.
2. The GC will conduct a legal sufficiency review and provide any feedback to the Policy Administrator.
3. The Policy Administrator will provide the Review Packet to the CCFPO or designee, who will determine if it is ready to proceed to PVP Review, and if so, will provide the Review Packet to the Special Assistant or designee.
E. PVP Review
1. Upon receipt, the Special Assistant or designee will provide the Review Packet to PVP.
2. PVP will provide feedback to the GC or designee who will work to incorporate any suggested revisions.
3. If the Policy Action relates to a Policy, PVP will reach a consensus as to whether to submit the Policy to the Board Committee. If PVP cannot reach a consensus, the President will decide whether to submit the Policy to the Board Committee.
4. If approved for submission to the Board Committee, the Special Assistant or designee will prepare the Approval Form.
F. Board Committee Review
1. The Special Assistant or designee will follow the Development Policy for submission of the Approval Form and Review Packet to the Board Committee.
2. After the Board Committee provides feedback, the CCFPO or designee will submit the revised Review Packet to the Review Panel, which is responsible for communicating with the Constituency Groups. The CCFPO or designee may provide an explanation as to the reason(s) changes proposed by the Review Panel were not included or revisions were made.
G. If substantive revisions are made at any stage of the review process, at the discretion of the President, the Special Assistant or designee may re-route the Review Packet for additional feedback and resolution.
IX. Policy Approval
A. After the Board votes, the Special Assistant or designee will complete the Approval Form.
B. If the Board approves the Policy, the Special Assistant or designee will:
1. Submit a clean copy of the Policy to the Policy Administrator for implementation or discontinuation;
2. Publish or remove the Policy on the College’s website on or before the Effective Date;
3. Archive any prior version of the Policy;
4. Maintain the Approval Form;
5. Calendar the next required review cycle, which shall be no more than five (5) years from the Effective Date; and
6. Request that the President may take action to approve the accompanying Procedures, if any.
C. If the Board declines the Policy, the Special Assistant or designee will:
1. Notify the Policy Administrator who will be responsible for determining if any further action is needed; and
2. Maintain the Approval Form.
D. Upon receipt, the Policy Administrator will notify the Drafting and Review Committees, and if approved, begin implementation, training, and communication in accordance with the Implementation Plan.
X. Procedure Approval
A. If the Policy Action relates solely to Procedures, 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.
B. 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.
C. After PVP considers the Procedures, the Special Assistant or designee will complete the Approval Form.
1. If approved, the Special Assistant or designee will:
a. Submit the approved Procedures to the Policy Administrator for implementation or discontinuation;
b. Update the Procedures 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.
2. If declined, the Special Assistant or designee will:
a. Notify the Policy Administrator, who will be responsible for determining if any further action is needed; and
b. Maintain the Approval Form.
3. Upon receipt, the Policy Administrator will notify the Drafting and Review Committees, and if approved, begin implementation, training, and communication in accordance with the Implementation Plan.
XI. Interim Procedures
A. The President delegates authority to the Policy Owner to approve a 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 described above, including but not limited to, 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 Policy 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 these Development Procedures 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 mark the Procedure as “Interim.”
Policy Title: Procedures 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@aacc.edu
Approval Date: Nov. 9, 2021
Effective Date: Nov. 9, 2021
History: N/A
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