I. Purpose
A. This 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, and the Board.
B. With the exception of the Shared Governance Policy and Procedures, this Development Procedure applies to all Policies, Procedures, Public Safety Protocols, and Guidelines created, revised, or discontinued after the Effective Date of these Procedures. Development of the Shared Governance Policy and Procedures shall be governed under the Policy and Procedure on Development of Policy and Procedures in effect at the time development of those Policy and Procedures began.
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. Drafter is a member of the General Counsel’s (GC) office or the Chief Compliance and Fair Practices Officer (CCFPO) assigned to the Drafting Committee by PVP to assist the Policy Administrator(s) in drafting and reviewing a particular Policy and/or Procedure, as described in Section IV.B.6.
4. Drafting Guidelines are guidance on how to draft or revise Policies and/or Procedures.
5. GC is a member of the General Counsel’s Office, as assigned by the General Counsel.
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 an online form used to seek a Policy Action.
9. Public Safety Protocol is a set of rules that govern the operation of the Department of Public Safety and Police.
10. 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.
3. The requestor will receive an email acknowledging receipt of the request.
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(s) 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, and the Policy Administrator assigned to each Policy and Procedure on the list. This list shall be available on the AACC intranet for review by all Constituency Groups and their members.
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 and Drafter may consult with Constituency Group leaders and Subject Matter Experts 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 and the Policy Administrator.
1. The Policy Owner will provide feedback to the GC or designee and the Policy Administrator 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 requested to provide timely feedback on every Policy and Procedure whose implementation will significantly impact the college community, as set forth in Section B, below.
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 requested 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 requested to review every Policy and Procedure from an equity lens and will provide feedback to the CCFPO or designee.
B. Review by Constituency Groups
1. The CCFPO or designee will submit the draft Policy and/or Procedure to TFO, ASO, PSSO, and the CDEIO for review in the form and format determined by the CCFPO or designee. If appropriate, the CCFPO or designee will also submit the draft Policy and/or Procedure to SGA for review.
2. It is strongly recommended that Constituency group leaders discuss the draft Policy and/or Procedure with Constituency Group members in a manner that is appropriate to the Constituency Group.
3. Members of Constituency Groups, the CDEIO, and SGA, if applicable, will be given thirty (30) calendar days to provide comments or suggest changes (“Review Period”). The CCFPO may determine to provide additional review time if the College is closed during the review period.
4. At the end of the Review Period, the CCFPO or designee will submit the feedback received to the Drafting Committee.
5. 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.
6. The Policy Administrator may consult with the Policy Owner and/or PVP during the review process.
7. If necessary, the Policy Administrator will make changes to the Implementation Plan.
C. PVP Review
1. Once the feedback is incorporated into the draft, the Policy Administrator will provide the revised draft to the GC to review and provide the revised draft to PVP.
2. The Policy Administrator will provide PVP with a summary of comments received by the Drafting Committee, noting consensus and dissent about the draft document, together with the Policy Administrator’s recommended changes to the policy or procedure.
3. PVP will provide feedback to the GC and the Policy Administrator who will work to incorporate any suggested revisions by PVP.
4. 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.
5. If the Policy Action relates to a Policy, PVP will approve the Policy for submission to the Board Committee.
D. 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 Policy Oversight 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. Schedule the next required review cycle, which shall be no more than five (5) years from the Effective Date.
4. Upon receipt of an approved Policy, the Policy Administrator will begin implementation and communication in accordance with the Implementation Plan.
5. If the Board declines to approve the Policy, the Special Assistant or designee will:
a. Notify the Policy Administrator to determine if further action is needed;
b. Notify the Constituency Group leaders and the initiator of the policy request; and
c. Maintain the Approval Form.
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; and
e. Schedule the next required review cycle, which shall be no more than five (5) years from the Effective Date.
5. Upon receipt of an approved Procedure, the Policy Administrator will begin implementation and communication in accordance with the Implementation Plan.
6. If declined, the Special Assistant or designee will:
a. Notify the Policy Administrator to determine if further action is needed;
b. Notify the Constituency Group leaders and the initiator of the policy request; and
c. Maintain the Approval Form.
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 or 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 at the same time the final Policy or Procedure is posted.
VIII. 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 likely 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. Prior to approving an Interim Procedure, the Policy Owner will provide notice to leaders of the affected Constituency Group, and should seek input from an affected Constituency Group, through its leadership. 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. Public Safety Protocols
A. The College will maintain Public Safety Protocols.
B. Public Safety Protocols must be reviewed by a member of the GC’s office before being published.
C. Public Safety Protocols are not subject to this Procedure but must be approved by PVP before being published.
D. Once approved by PVP, the Special Assistant or designee will submit the Public Safety Protocols to be published on the College’s website on or before the Effective Date.
E. The Chief of Police will also submit the Public Safety Protocols to be published as required by the Maryland Police Training and Standards Commission.
X. 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@warocolor.com
Approval Date: June 3, 2024
Effective Date: June 5, 2024
History: Approved Nov. 9, 2021; Interim approved on June 12, 2023; approved March 24, 2024; Interim approved on June 3, 2024
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