Procedure

University Policy on Policies

PURPOSE

To establish standards for the development, approval, revision, and decommissioning of University Policies for the Storrs and Regional Campuses, and institution-wide policies that affect all campuses, including UConn Health. This policy aims to ensure that University policies are well defined, understandable, consistent with the University’s mission, values, and goals, and sanctioned by the University’s administrative authorities through standardized processes.

DEFINITIONS

Guideline: Recommended guidance or additional information used to support policies and procedures, industry best practice, or intended to educate the workforce on how to achieve a desired outcome. Allows end-user discretion in interpretation, implementation, or use. Non-compliance with, or violation of, guidelines does not create the same level of risk.

Policy Owner: The unit, senior institutional official and/or designee responsible for authoring, implementing, maintaining, and monitoring a policy.

University Senior Policy Council: The University Senior Policy Council is a standing committee whose role is to review and approve new and revised University policies.  The Senior Policy Council is comprised of the University President; Executive Secretary to the Board of Trustees; Chief of Staff; General Counsel; Chief Compliance Officer, Chief Human Resources Officer, Provost, and the Vice President for Finance and Chief Financial Officer.  Others may be invited, as necessary.

Procedures: Operational processes established for the implementation of policies. If a policy is “what” the institution does, its procedures are “how” it carries out the requirements of a policy. Non-compliance with, or violation of, procedures may result in disciplinary action.

Procedures

  • outline required actions by objective and/or job function;
  • state clearly and succinctly the step-by-step instructions that must be followed to implement policy effectively;
  • specify the structure to enforce the policy;
  • University Policy procedures shall not be revised without consultation with the Office of University Compliance.

Revision, Editorial: Includes modifications related to spelling, grammar, format, and updates to hyperlinks or URLs, contact information, references, titles of individuals and organizations.

Revision, Non-substantive: Includes modifications intended to enhance clarity without changing the intent of the policy, such as adding or modifying definitions, rearranging or re-wording sentences without changing their meaning or the policy’s requirements for compliance.

Revision, Substantive: Includes significant modifications to the nature and/or scope of the policy that affect its requirements, principles, or intent.

Senior Institutional Official (SIO): The appropriate University officer (Vice President, Vice Provost, or similar) who has authority and responsibility for the area or activity to which a policy may apply.

Stakeholder: University members with expertise in the subject matter of the policy, or whose operations will be significantly affected by the policy.

University Policy: An official statement expressing the position of the University on an issue of university-wide importance. A university policy

  • is a governing principle that mandates or constrains actions, establishes rights or obligations, or guides the decisions and actions of the University;
  • has broad application;
  • exists to achieve compliance with applicable laws, regulations, and organizational requirements; to promote operational efficiencies; to enhance the University’s mission; to reduce institutional risk; and/or to promote ethical standards, integrity and accountability;
  • is approved by the administrative authority of the University and/or the Board of Trustees

Policies that do not fit the criteria of a University Policy, such as individual unit policies, should be vetted through the appropriate Dean or Director for approval to ensure consistent application and to avoid conflict with any University or unit policies. Unit policies, procedures and guidelines shall not subvert, supersede, or contradict University Policies. Units should use a similar policy review process as outlined in this document. Please contact the Office of University Compliance or refer to the Policy website for assistance.

POLICY STATEMENT

All University Policies shall be developed, approved, revised, and decommissioned in accordance with the procedures outlined in this Policy. In rare circumstances, exceptions to this process may be approved by the President in consultation with the University Senior Policy Council and notification to the Board of Trustees as may be warranted.

Individual units (e.g., colleges, schools, centers, institutes, departments) may create, communicate, maintain, and enforce policies that are applicable to their respective authority, as long as these are not in conflict with official University Policies.

PROCEDURES

I. New University Policy
II. Revising a University Policy
III. Decommissioning a University Policy
IV. Archiving University Policy
V. Expedited (Emergency) Policy Approvals

 

I. New University Policy

1. Determine Need
A. University Policies should only be created when they define University values, institutional objectives or mandates; address federal or state law, regulations, or rules; or manage potential risk or liability.
B. Any individual or unit may identify the need for a new University Policy. However, a Senior Institutional Official, in consultation with the Office of University Compliance, must confirm the need for the policy considering

  • whether the proposed policy meets the criteria of a University Policy as defined;
  • if an alternative such as workforce guidance or procedures is the most effective and efficient approach;
  • if existing University policy addresses or resolves the identified need;
  • implications of the policy including risks and costs (i.e., will adoption of the proposed policy require new resources or reassignment of existing resources?)

2. Development
A. If a proposed policy involves matters within the purview of more than one senior institutional official, they will ensure consultation and coordination among appropriate leadership.
B. The Senior Institutional Official may assign the development and administration of the policy to a responsible office or individual (Policy Owner).
C. The Policy Owner is responsible for developing a draft policy in consultation with key stakeholders and University governance groups (e.g., University Senate, Deans Council). It is advisable that the Policy
Owner convene a stakeholder policy development group to provide initial vetting of the proposed policy.
D. University policy

  • must follow the Policy Template [link];
  • should be written so that it is clear and concise with sufficient information on the subject without being excessive in length or complexity;

3. Engage the Office of University Compliance
A. Early in the development stages, the individuals or groups developing the policy must notify the Office of University Compliance.

B. University Compliance is responsible for

  • stewardship of the policy development process to ensure consistency with existing policies, language, clarity, format and appropriate vetting and approval;
  • engaging the Office of the General Counsel as appropriate;
  • reviewing stakeholder and partner input;

4. Approval
A. Although the development or administration of a policy may be delegated, the SIO is responsible for ensuring all necessary approvals are obtained.

B. Once the SIO is satisfied with the final policy draft, it must be forwarded along with a list of stakeholder reviewers to University Compliance at policy@uconn.edu. University Compliance may consult with the Office of General Counsel for final review.

C. For policies that apply to the Storrs, Regional and UConn Health campuses, University Compliance will coordinate review and approvals with the appropriate UConn Health policy committees before
advancing the policy to the Office of the President.

D. University Compliance will work with the Office of the President and the SIO to present the draft policy to the University Senior Policy Council for their review and recommendation to the
President. There may be occasions when a University Policy requires review and approval by the Board of Trustees prior to adoption.

E. The President, in consultation with the Senior Policy Council, will make the final determination regarding when a University Policy shall be presented to the Board of Trustees for approval. If
so, the proposed policy will typically be assigned to one or more standing Board committees to review and approve before the proposed policy goes to the full Board for final approval.
University Policies that advance to the Board for approval are often those that relate to:

  • University governance and describe the composition, powers, and duties of the Board of Trustees, the President, or University Senate;
  • University By-Laws (e.g., academic appointment and tenure; grievances; leaves of absence; naming of facilities; intellectual property; the establishment of new regional campuses,
    schools or colleges; expressions of dissent; and student residency);
  • Code of Conduct;
  • high-level university financial operations such as investments and the establishment of, or significant changes in existing, major University fiscal policies (e.g., capital expenditures).

5. Publication & Notification
A. Once the University Policy has been approved, the SIO will collaborate with University Compliance to ensure the policy is posted to policy.uconn.edu (and health.uconn.edu/policies where
applicable.

B. The SIO shall oversee the communication, implementation, training, administration, and maintenance of the University Policies within their purview. The SIO must publicize and distribute the
policy to the University community members to whom it applies and to offices with implementation requirements.

C. Policies published to the University’s Policy site are the official and current versions.

D. Members of the University community are responsible for familiarizing themselves and complying with University Policies.

E. All new University Policies not requiring Board approval shall be shared with the Board of Trustees at the next regularly scheduled meeting as an informational item.

 

II. Revising a University Policy
Regularly reviewing policies and procedures ensures that the University’s operations and administration are

  • in compliance with new laws and regulations;
  • current with new systems or technology;
  • consistent with best practices.

1. Review
A. Policies must be reviewed at least once every three (3) years, or sooner if legal or regulatory requirements or changes in operational processes deem necessary. The senior institutional official,
or designee, must ensure the periodic review and revision of policies related to their areas of responsibility.

B. University Compliance monitors policies for compliance with the required review schedule.

C. The senior institutional official must notify University Compliance at policy@uconn.edu

  • of necessary changes by providing a strikethrough or “redline” copy of the policy with proposed revisions;

OR

  • if review was conducted and there are no necessary changes.

    D. The date of review, even in the absence of revision, shall be noted in the Policy History of the document.

    2. Revision Approvals
    University Compliance, in conjunction with the senior institutional official, will determine if the proposed revisions are editorial, non-substantive or substantive.

    • A. Editorial revisions will be completed by University Compliance.
    • B. Non-substantive revisions will be completed by University Compliance after notifying the University Senior Policy Council.
    • C. Substantive revisions must follow the same review and approval process as a new policy.

     

    III. Decommissioning a University Policy:
    When a policy is no longer needed or is more effectively combined with another policy, the responsible office will submit a formal request to the senior institutional official responsible for the policy. The senior institutional official shall confer with applicable University governance groups and subject matter experts as appropriate to ensure overall impact is considered.  The senior institutional official will collaborate with University Compliance to seek formal decommissioning approvals. If there is disagreement as to whether a policy should be decommissioned, the University Senior Policy Council will decide.

    University Compliance will remove decommissioned policies from the policy.uconn.edu website and inform the Senior Policy Council quarterly of decommissioned policies.

     

    IV. Archiving a University Policy:
    University Compliance will work with University Archives to properly maintain the record. Policy Owners are strongly encouraged to retain policy records.

     

    V. Expedited (Emergency) Policy Approvals
    The expedited policy approval process is reserved for policies that the President or the Senior Policy Council deem crucial for the health and safety of the University community, the continuity of University operations, to address legal requirements or significant institutional risk and, therefore, must be processed in a shorter time than possible through the established approval process.

    In such cases,

    • the President or the Board of Trustees identifies an emergency policy need and assigns a senior institutional official;
    • the stakeholder review process may be bypassed, but the draft policy must be reviewed by the Senior Policy Council;
    • the Senior Policy Council shall consider any immediate and significant impact on operations;
    • emergency policies that apply to UConn Health shall be provided to the appropriate policy committees for expedited review and approval.

    Unless a duration is specified in the Expedited Policy, all Expedited Policies will be reviewed in one (1) year by the Senior Policy Council to determine whether the policy should be extended, made permanent, or decommissioned.

    POLICY HISTORY

    Approved on March 30, 2022, by the Board of Trustees

    UConn’s NAGPRA Procedure

    University of Connecticut NAGPRA Procedures:

    The Provost will designate one or more persons at the University to help administer the University’s compliance obligations under NAGPRA.  That person(s) is referred to as the “NAGPRA Coordinator(s)” for purposes of these procedures. The NAGPRA Coordinator will be responsible for working in close consultation with lineal descendants and Native American and Native Hawaiian organizations in identifying any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony that are maintained by the University, and on determinations of cultural affiliation and repatriation of Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony, that are part of the University’s collections.

    NAGPRA Review Group

    The Provost will establish a NAGPRA review group to assist the NAGPRA Coordinator in the administration of the University’s compliance obligations under NAGPRA and to report recommendations on cultural affiliation and repatriation to the Provost.  This review group will be chaired by an appointee designated by the Provost and will include the State Archaeologist, members from the Department of Anthropology and the Connecticut State Museum of Natural History and other offices at the University who maintain human remains, funerary objects, sacred objects, or objects of cultural patrimony.  The representatives of the review committee will be responsible for communicating and involving the departments, museums and other University offices they represent on matters relating to the University’s compliance obligations under NAGPRA.

    Use of Human Remains in Teaching and Research

    The NAGPRA review group must be notified of any teaching or research being conducted at the University or by faculty or staff from the University that involves the use of Native American or Native Hawaiian human remains.

    NAGPRA Collections

    The NAGPRA Coordinator will work with the NAGPRA review group and departments, museums and other University offices to help maintain a centralized record of all Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University, such record will include the location(s) of the relevant items and any NAGPRA-related reports or communications relating to such items.

    NAGPRA Reporting & Process Initiation

    The NAGPRA Coordinator will inform the NAGPRA review group and the Provost upon becoming aware of any Native American and Native Hawaiian human remains and cultural items maintained by the University that were not previously reported under NAGPRA.  The NAGPRA Coordinator will initiate a NAGPRA process for any Native American and Native Hawaiian human remains and cultural items maintained by the University.  This will include consulting with lineal descendants and Native American and Native Hawaiian organizations prior to making any recommendation as to cultural affiliation or repatriation.  The NAGPRA Coordinator must consult with the NAGPRA review group and the Provost’s office prior to completing a summary or inventory under NAGPRA.

    Cultural Affiliation Recommendations

    The NAGPRA Coordinator will make a proposed recommendation of cultural affiliation, when appropriate, for any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University to the NAGPRA review group.  The NAGPRA review group will review and evaluate such recommendations.

    The chair of the NAGPRA review group will submit a proposed recommendation of cultural affiliation, reflecting the initial recommendation provided by the NAGPRA Coordinator and the comments of the NAGPRA review group, to the Provost.  The Provost is the only University official authorized to make determinations of cultural affiliation under NAGPRA with respect to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University.

    Repatriation Recommendations

    The NAGPRA Coordinator will be responsible for identifying appropriate claimant(s) and making a proposed recommendation of repatriation, when appropriate, for any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University to the NAGPRA review group.  The NAGPRA review group will review and evaluate such recommendations.

    The chair of the NAGPRA review group will submit a proposed recommendation of repatriation, reflecting the initial recommendation provided by the NAGPRA Coordinator and the comments of the NAGPRA review group, to the Provost.  The Provost is the only University official authorized to make a recommendation of repatriation under NAGPRA with respect to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University.

    Consumable Supplies Inventory Procedure

    Title: Consumable Supplies Inventory Procedure
    Procedure Owner: Office of the Controller, Accounting Office
    Applies to: All University Departments
    Campus Applicability: Storrs and Regional Campuses
    Effective Date: 09/01/2016
    For More Information, Contact Associate Controller and Director of Accounting
    Contact Information: (860) 486-3780
    Official Website: http://accountingoffice.uconn.edu/

    BACKGROUND AND REASON FOR PROCEDURE

    An inventory of consumable supplies is reported annually to the Office of the State Comptroller (OSC) on the Annual Inventory Report of all Real and Personal Property (CO-59) form. Consumable supplies must be safeguarded and managed in order to prevent excessive spending and loss.

    DEFINITIONS

    Consumable supplies are defined as stock items used and consumed in the daily operations of a UConn department, such as food, cleaning supplies, lab animals, perishables, table or bed linens, repair parts, small tools, small appliances, and articles of a similar nature. Items should be new and unopened, and which will be used up within a year. Consumable supplies does not include capital equipment or controllable property equipment.

    PROCEDURE

    1.  For all departments with a consumable supplies inventory of $5,000 or more, a separate perpetual (continuous) inventory should be maintained.
    2. A physical inventory must be performed annually and reconciled to the inventory records by June 30th.
    3. A listing of consumable supplies must be reported to the Accounting Office within the Office of the Controller by July 15th. The inventory listing should include an item description, cost, unit of measure, quantity on hand, and a total cost for each item, by location/building.
    4. The inventory listing and signed Inventory Certificate Form may be sent by email or through the University mail service to the Accounting Office at U-1074.

    FORMS/TEMPLATES

    An Inventory Worksheet (Excel template) may be used to report inventory. Alternatively, departments may submit a report generated from an inventory system maintained by the department.

    The Inventory Certificate Form is available on the Inventory Control website.