With the end of the spring school term fast approaching and summer right around the corner, colleges and universities have an opportunity to turn attention to creating, revising, updating and preparing policies, procedures and disclosures for the fall school term. As opposed to changing policies and procedures mid-school year, having compliant policies and procedures ready to go from the start of the school term allows consistent application throughout the school year. Below is a non-exhaustive checklist of some key items colleges and universities should ensure are up-to-date for fall 2015.
- Title IX & VAWA Policies and Procedures (reporting, rights, process, etc.)
- ADA/Section 504 Policies and Procedures
- Clery Act Compliance
- Student Disclosures (FERPA, Consumer Information Notice, Drug and Alcohol Notification, etc.)
- Emergency Response System (test at beginning of school year)
- Admissions Information (websites and printed materials)
- Student Handbook (student conduct, academic integrity, etc.)
- Program-Specific Handbooks
- Faculty Handbook
- Employee and Staff Handbook
- Data Privacy (policies, breach response plans, etc.)
- Faculty, Staff, and Student Training (online/in-person – Title IX, FERPA, Clery, disability accommodation, research compliance, etc.)
- Policy Administration Procedures (systems for revising, archiving, and disseminating policies and procedures)
What this means to you
Institutions can take steps to increase effectiveness and limit potential liability by maintaining and making available compliant policies, procedures and disclosures. Although the details of policies, procedures and disclosures have a tendency to be overlooked when they are not at issue, they will be scrutinized in the event of a complaint or investigation into alleged wrongdoing. Courts have shown a propensity to be deferential to institutional decision-making when institutions follow their own, current policies. Therefore, maintaining compliant policies and procedures and properly disclosing the same can be the difference between a determination that an institution was justified in its actions and a finding that it failed to meet its obligations.