Develop an interim policy process for extenuating circumstances

**The views expressed in this blog are my personal views and do not represent the official position of Metropolitan State University of Denver or ACUPA.**

When I drafted the expedited policy clause in Metropolitan State University of Denver’s “policy on policy,” which allows the MSU Denver president to enact interim policies “to address legal requirements or a significant institutional risk,” I did not have a worldwide, coronavirus pandemic in mind. However, as the daughter of two Vietnam vets and the wife of a military historian, I knew that an organizational threat might come from somewhere (or something) unexpected.

Balancing Inclusivity and Operational Effectiveness

MSU Denver’s policy process is designed to be inclusive and transparent. New and revised policies are reviewed by MSU Denver’s President’s Cabinet, by students and employees who serve on the Policy Advisory Council, by the shared governance groups, and by the university community at-large during an open review period. The inclusive process balances efficiency with effectiveness, in that publishing a policy quickly might not mean that a policy is communicated and implemented effectively.

Some circumstances, however, require quick, decisive action when it comes to policies. To address the current situation, MSU Denver’s leadership has instituted several interim policies related to moving courses online, working remotely, and allowing flexible grading options for students for the spring 2020 semester. Policies that were already in the works, such as a new social media policy, are still moving through the inclusive process, with meetings and document review occurring online.

Full Process

• Decision maker: Board of Trustees, president, or provost
• Review/Input:
  • Board of Trustees (for governance policies)
  • President’s Cabinet
  • General counsel
  • Policy Advisory Council
  • Student Government Assembly
  • Faculty and staff senates
  • University community open comment period
  • Ad hoc work groups based on expertise and operational area
• Documentation: Formal policy statement published online in University Policy Library

Interim Process

• Decision maker: President or provost
• Review/Input: Key constituents at president’s or provost’s discretion (in this case, a cross-functional taskforce, including the provost, general counsel, senior leadership team, and others was formed to address all things COVID-19)
• Documentation: Informal policy statements published online in the employee newsletter and MSU Denver’s COVID-19 Updates and Resources webpage

Staying Flexible

Including some flexibility in the policy process has saved me a great deal of stress during this time, as it allows me to focus on ongoing operations as senior leaders within the organization address current developments.

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.