Policy Compliance Process

If you are proposing a new or revised Official University Policy, please follow these steps:

Step 1: Sponsoring Unit and Key Stakeholder Collaboration

Responsible Parties: Sponsoring Unit (SU), Affected Units (AU), Office of General Counsel (OGC)

Process:

1. The Proposed Policy is drafted using the Policy Template.
2. The Sponsoring Unit consults with OGC (OGCRMcontracts@drexel.edu) to ensure Policy Compliance.
3. The Sponsoring Unit collaborates with the Faculty Senate (senate@drexel.edu) and AU to gain buy-in.
4. The Sponsoring Unit submits the following documents to policy@drexel.edu:
   • Intake Form [PDF]
   • Communication Plan [PDF]
   • Proposed Policy (No Track Changes)
   • Original Policy (Track Changes - Redlined)
   • Summary of Policy Changes

The Director of Policy Compliance (DPC) logs the Proposed Policy and ensures its review.

Timeline: Not Tracked

Step 2: Office of General Counsel (OGC) First Review

Responsible Parties: SU, DPC, OGC

Process:

1. DPC ensures the OGC completes an initial legal review.
2. OGC reviews for duplications and compliance (two weeks).
3. SU reconciles Policy based on OGC feedback (two weeks).

Timeline: Four Weeks

Step 3: Sponsoring Unit Prepares Policy for Stakeholder Engagement

Responsible Parties: SU, DPC

Process: SU reviews and finalizes the draft for stakeholder engagement and sends the reconciled documents to DPC.

Timeline: Two Weeks

Step 4: Stakeholder Review Process

Responsible Parties: SU, Academic Council (AC), Faculty Senate (FS), Policy Council (PC), DPC

Process:

1. First Review: Stakeholders (AC, FS, FS) review the Proposed Policy (six weeks).
2. Reconciliation: SU reconciles feedback from Stakeholders (two weeks).
3. Second Review: Stakeholders review revised Policy (six weeks).
4. Final Reconciliation: Sponsoring Unit reconciles feedback (two weeks).
5. DPC sets up the Public Comment Period (two weeks).
6. Public Comment Period opens (30 days).
7. Policy Council reviews public comments (one week).
8. Sponsoring Unit reconciles public comments (one week).

Timeline: 24 Weeks

Step 5: OGC Second Review

Responsible Parties: SU, OGC, DPC

Process:

1. Sponsoring Unit submits final policy draft to OGC.
2. OGC ensures legal compliance (2 Weeks).
3. Sponsoring Unit reconciles policy (2 Weeks).

Timeline: Four Weeks

Step 6: Cabinet and Presidential Review

Responsible Parties: DPC, President’s Cabinet, SU

Process:

1. DPC sets up the voting survey for Cabinet and President.
2. Cabinet reviews and recommendations (1 Week).
3. The President reviews and approves policy (1 Week).

Timeline: Two Weeks

Step 7: Implementation of the Communication Plan

Responsible Parties: SU, DPC

Process:

1. Approved Official University Policy is published in the SharePoint Policy Directory.
2. The Communication Plan is implemented.

Timeline: One Week

Step One: Sponsoring Unit and Key Stakeholder Collaboration

The Sponsoring Unit notifies key stakeholders of the intention to revise or create an Official University Policy:

• Faculty Senate (senate@drexel.edu)
• Office of General Counsel (OGC)
• Affected Units
• Office of Policy Compliance (policy@drexel.edu)
• The Sponsoring Unit collaborates with OGC, Faculty Senate, and Affected Units to review the need for expedited processing and initial Policy considerations.

Timeline: No fixed timeline (varies by complexity and stakeholder feedback).

Step Two: Statement of Intent to Expedited Submission

The Sponsoring Unit submits the following documentation to the Director of Policy Compliance Services (DPC):

• Intake Form [PDF]
• Communication Plan [PDF]
• Proposed Policy (No Track Changes)
• Original Policy (Track Changes - Redlined)
• Summary of Policy Changes

The DPC begins the review process by initiating the following actions:

• Shares the with Faculty Senate and requests feedback within one week

Timeline: Approximately one week

Step 3: Policy Council Review

The DPC presents the justification for an Expedited Review to the Policy Council.

• The Policy Council reviews the documentation and determines whether the Policy qualifies for Expedited Review.
• The Policy Council provides a recommendation.

Criteria for Expedited Review

The Drexel Policy Council may approve a Policy for expedited review ONLY under the following circumstances:

• The Policy addresses changes in laws or legal requirements.
• The Policy is needed to resolve non-compliance with legal, regulatory, or enforcement mandates.
• There is insufficient time to complete the full Policy review process due to urgency.

Timeline: One Week

Step 4: OGC Review

Following the Policy Council’s recommendation, the Director of Policy Compliance (DPC) submits the proposal to the Office of General Counsel (OGC). OGC then conducts a thorough legal review to ensure compliance and provides a formal recommendation.

Timeline: Two Weeks

Step 5: Cabinet's Review and Presidential Approval

If OGC approves the proposal, the Director of Policy Compliance (DPC) presents the following to the President’s Cabinet for review:

• Communication Plan [PDF]
• Proposed Policy (No Track Changes)
• Original Policy (Track Changes - Redlined)
• Summary of Policy Changes

The Cabinet evaluates the proposal and provides a recommendation to the President. The President reviews and makes the final decision on Policy approval.

Timeline: Two Weeks

Step 6: Implementation of the Communication Plan

Once approved by the President:

1. The DPC:
   • Updates the Policy in the Official Policy Directory.
   • Marks the Policy as “Interim” (if applicable).
   • Archives previous versions in designated systems (e.g., Teams, shared databases).
2. The Sponsoring Unit implements the approved communication plan to notify all relevant stakeholders and units of the Policy change.

Timeline: Three Days

To increase community engagement in Drexel’s policy-making process, all proposed Official University Policies undergo a 30-day public comment period before the President’s Cabinet and the President review the final draft.

All students, faculty and professional staff are invited to review and comment on the proposed policies listed on the Public Comment Period SharePoint (Drexel credentials required to view). Follow the links provided on the SharePoint to review the policy drafts and provide your comments via Qualtrics.

The Policy Council will review all comments and determine if modifications are needed. There is no assurance that a policy will be modified based solely on comments, nor will there be an individual response to each comment.

If you have any questions or concerns, email policy@drexel.edu. The open and close dates of public comment periods will be announced on the Public Comment Period SharePoint, the University Events Calendar, and the “It’s Okay to Ask” compliance e-newsletter.

Official University Policies sometimes become outdated, obsolete or superseded by a new policy. In these instances, the policy that is no longer needed must be decommissioned through the following process prescribed by the Official University Policies policy (DU–01).

1. The Sponsoring Unit should consult with any Affected Units and the Office of the General Counsel to determine whether decommissioning is warranted.
2. If warranted, the Sponsoring Unit must submit a completed Statement of Intent to Decommission an Official University Policy [PDF], including a communication plan, to the Director of Policy Compliance.
3. The Director of Policy Compliance presents the proposed decommissioning to the Policy Council for review.
4. If the Policy Council recommends decommissioning the policy, the Director of Policy Compliance and the Sponsoring Unit will present the proposal to Cabinet for review and recommendation to the President.
5. Upon final approval by the President, the Director of Policy Compliance will handle removing the decommissioned policy from the Policy Directory and archiving it in the appropriate systems, while the Sponsoring Unit will implement the decommissioning communication plan.