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Where Does Your Policy Function Belong?

Posted By Joshua Adams, Cornell University, Monday, February 4, 2019
Updated: Wednesday, February 6, 2019

Reorganization of Policy Administration at Cornell


I am continually surprised by the different organizational placement of so many of our policy offices. When the ACUPA membership was surveyed, we found that organizational placement under executive administration or compliance/risk management made up more than half of those offices responding, with another 23% reporting through general counsel and finance.  The balance of the responding offices were in HR, academic/research, or various other areas, with no single one representing more than 6% of total responders.

Where do you report in your organization, and does it matter?  Is the success of institutional policy at your organization necessarily tied to any particular organizational structure, such as the existence of a central compliance function? Could you have any influence if you believed that your policy function needed to be moved in your organization in order to be successful? To whom would you appeal, if you did want to move your office to another organizational unit? These are the questions many of us ask ourselves, and ones I have asked myself regularly for well over twenty years. 

Here at Cornell University, the policy function began in 1989, when “higher education policy” was viewed skeptically, at best, and considered Orwellian by many. We were originally part of the internal audit office.  Within a few months, however, senior administration realized that this placement created a conflict of interest: the same individuals who were responsible for the process for developing the policies couldn’t objectively audit against them. So we looked for a new home.  Thankfully, we had a willing vice president for financial affairs, who took over responsibility for institutional policy.  And there we lived—until three weeks ago.

While I’m fairly certain it was not because of my long-held opinion that the university should consider moving the policy function out of the finance area, it appears as though this is the direction the university is headed.  A new chapter has begun for me at the university and, as of now, the policy office reports to the “associate vice president for EH&S and risk management,” a big title for a growing university unit.  Formerly just “Environmental Health and Safety” (EH&S), the unit expanded some months ago to include the area of risk management and insurance and, now, university policy. Cornell does not have a centralized compliance office, and I wonder if that might be the next function to join our unit.

I’m excited about the change, and I look forward to a renewed effort on policy, from the vantage point of institutional risk.  Already, I have begun meeting with the office of risk management to chat about creating “risk registers” and learn about how cooperation between the two areas will drive policy that is stronger, leaner, and more focused.

As you are developing or strengthening your policy process, and considering where the policy function properly belongs at your institution, what factors are the most important? Are you where you should be and, if not, how do you advocate for the policy function in the best interest of your institution? Unfortunately, I don’t have the “correct answers” to these questions; however, if we continue the dialogue, we will undoubtedly gain valuable knowledge together that will help us all achieve our professional goals.

Tags:  Collaboration  Governance  Policy Administration 

Permalink | Comments (8)
 

Comments on this post...

Cara O'Sullivan, Utah Valley University says...
Posted Monday, February 4, 2019
This is a great question. AT UVU, the Policy Office was once held by one person who doubled as compliance officer. As the university grew (we have been a university for only about 10 years), it was decided to separate out the policy office function. Compliance now reports to the Office of General Counsel and the Policy Office reports up to the VP of Budget, Planning, and HR.

Our policy office is primarily an editing, training, and project management entity.

I don't think there is one universal spot for a policy office function--it depends on the nature of the institution and where that institution is at in its evolution.
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Pat Dean-Love, University of Kansas Medical Center says...
Posted Monday, February 4, 2019
At KU Medical Center our policy function is part of the Compliance Program, under the Office of Compliance, which is a sub area of Compliance Services which includes EHS and a few other areas. http://www.kumc.edu/compliance-services.html
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Bonnie Leigh Reifsteck, University of New Mexico says...
Posted Monday, February 4, 2019
A very timely topic! Thank you, Josh. UNM's Policy Office was created in 1990, and until this year reported to the EVP for Finance and Administration. We now report to the Office of University Counsel. It has been a tricky transition, to be honest, and I do worry at times about some conflict of interest. The transition came at a time of major leadership overhaul at UNM. We do have a separate Compliance Office, created within the last 5 or so years, which reports to the University President/Board of Regents - and has also experienced transitions in leadership over the last year. All to say, I've done a lot of thinking and researching on this topic, and I also don't know the correct answer(s)! It's certainly been an exercise in balancing collaboration with voicing my concerns, and balancing advocating for policy with accepting change.
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Seth Beccard, University of Minnesota says...
Posted Monday, February 4, 2019
Josh, thanks for the article. When we started out (about two years after Cornell), we were associated with the VP for Finance. At that time, that VP recognized the value of a structured, centralized policy library. However, having it point to just one VP allowed other areas to pick and choose what they liked out of the structure. Eleven years ago, after a comprehensive review of the program, we were realigned with the President's Office (reporting directly to the Compliance Office.) It was a perfect move for bringing in the consistency across policy topics.
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Teresa Raetz, Georgia Gwinnett College says...
Posted Tuesday, February 5, 2019
Hello all! I report to the executive director of plans, policies, and analysis (a unit that primarily deals with IR/IE, co-curricular assessment, accreditation, and strategic planning). The unit reports under the president, specifically to the chief of staff. I do think where you report matters. Show me your institution's budget and org chart, and I'll show you its values.
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Teresa Raetz, Georgia Gwinnett College says...
Posted Tuesday, February 5, 2019
Oops, need to clarify (the caffeine has apparently worn off). I don't think there's one right place for a policy function to report. I do think the reporting line should be such that the staff have the right political cachet or position in the institution to be effective. That varies by campus, most likely.
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Christopher Viggiani, Oregon State University says...
Posted Tuesday, February 5, 2019
Interesting post josh, and good luck! Initially, OSU's policy function sat within our University Compliance office. Recently, our compliance function has been folded into our office of audit and enterprise risk management. Recognizing the conflict that you noted in your post, we chose to place the Policy office within the Provost's Office--the thinking was that policy was "decisional" in nature and should reside with an executive, rather than an advisory function like audit or OGC (even though they are logical homes in some ways). Having thought about this a fair bit, I think there are a number of ways to organize a policy shop so it is effective and it will depend on the specific organization of your institution. Regardless of how the specific org chart looks, I think a policy program needs 1) engaged leadership that supports the policy mission and 2) strong relationships with audit, compliance, and general counsel.
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Anthony Graham, University of Pittsburgh says...
Posted Wednesday, February 6, 2019
I have thought about this quite a bit as well. The University of Pittsburgh policy function has moved from Finance to our Office of General Counsel in the last year. Not because of anything I did either.

Christopher Viggiani makes good points, which I agree with. Having the leadership engaged in the policy process and including users of the policy are key components. Our previous CFO was a long-time employee and had the confidence of the executive group. With some significant changes to our executive team, including a new CFO, the policy office moved to the Counsel’s office.

It seems like you are heading down a centralized Governance, Risk, and Compliance (GRC) path. We have evaluated a few GRC Systems and the processes in the systems were all driven off policies. We didn’t move forward with any of the systems because we do not have a centralized risk/compliance area. You may be reporting to a new area of the organization, but my guess is that there may be a different utilization of the policies based on the risk analysis that will be done and any development of a centralized risk area.
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