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November 2022 Policy Distribution, SYS Policy Approval Notice, and Effective Date Reminder

Posted 10:20 a.m. Tuesday, Nov. 22, 2022

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The November 2022 institution policy distribution includes for comment four (4) revised policies.


This email is going to Chancellors, Provosts, CBOs, SSAOs, SDOs, SSEOs, CHROs, CIOs, Purchasing Directors, Compliance Officers, Shared Governance Groups, and Designated Institutional Policy Contacts. Please distribute to others as needed.

November Policy Distribution, SYS Policy Approval Notice, and Effective Date Reminder


The November 2022 institution policy distribution includes for comment four (4) revised policies.

Four (4) revised policies: 

·         SYS 346, Patents and Inventions

·         SYS 521, Authority to Sign Procurement Contracts in the UW System

·         SYS 523, Emergency Procurements

·         SYS 540, Non-Competitive Procurement Contracts

Click on the links above to view the drafts and ensure that your feedback is captured for review during the post-comment period. Comments can include attachments, including word documents and PDFs.

Please submit your feedback by:

·         Friday, December 9, 2022 for SYS 521, SYS 523, and SYS 540

·         Tuesday, January 17, 2023 for SYS 346

Please find summaries of the policies and procedure below. 



DRAFT REVISED POLICIES

SYS 346, Patents and Inventions

This policy establishes the applicable UW System policies with respect to inventions and outline the responsibilities, privileges, and options of faculty, staff, and students when they have made an invention. Revisions to the policy include:

·         In Section 2, updated the responsible UW System Officer to the Vice President for Finance and Administration to reflect the recent reorganization of the UW System Administration.

·         In Section 5, updated the definition of invention to ensure it is comprehensive.

·         In subsection 6.A, added examples of inventions and updated language related to documentation.

·         In subsection 6.A, identified provisions that must be included in employee agreements related to their sponsored research projects.

·         In subsection 6.A, added references to sample agreements that may be used.

·         In subsection 6.A and 6.B, added new and revised existing language to ensure consistency with the Bayh Dole Act.

·         In subsection 6.B.III, added language related to special consideration for disposition of rights to unencumbered inventions which are embodied in tangible form.

·         In Section 7, added links to sample intellectual property agreement forms.


DRAFT REVISED POLICIES

SYS 500 Series Package

These policies are proposed for revision in response to amendments made to Regent Policy Document 13-1, General Contract Approval, Signature Authority, and Reporting, approved by Resolution 11895 on June 10, 2022. For details on the specific revisions proposed in each policy, see below:

SYS 521, Authority to Sign Procurement Contracts in the UW System

·         Throughout the policy, updated the citation formatting to the Wisconsin Statutes to align with other SYS policies.

·         In Section 4.A, removed language regarding Wisconsin’s Department of Administration delegating contract signature authority to sign contracts, and simplified language regarding Director of Procurement titles.

·         In Section 5, removed “Procurement” from the term Contract Signature Authority.

·         In the first paragraph of Section 6, clarified that procurement contracts must follow an authorized process, replaced “purchasing agent” with contracting personnel, and replaced language regarding the state procurement delegation policy and the delegation of authority agreement with a reference to RPD 13-1, General Contract Approval, Signature Authority, and Reporting.

·         In the third paragraph of Section 6, clarified that contracts must be signed by formally delegated university contracting personnel, and added the President as an individual who can delegate procurement contract signature authority. Also added that delegated personnel must confer with Purchasing personnel when determining the appropriate procurement authority, removed language that designated that this authority would be the state of Wisconsin or Board of Regents, and clarified that Purchasing must conduct the appropriate procurement process. In the last sentence, replaced the term “officer” with personnel.

·         Removed the fourth paragraph of Section 6 regarding University Contracting Officers not having the authority to sign state of Wisconsin procurement contract documents.

·         In the last paragraph of Section 6, removed the words “to monitor” to simplify language.

SYS 523, Emergency Procurements

·         In the last paragraph of Section 6, changed language from "must" to may, and removed the sentence dictating that contracts over $1 million require the Board of Regents approval.

SYS 540, Non-Competitive Procurement Contracts

·         In Section 1, added language to correct fragment sentence.

·         In Section 5, removed reference to Cost and Price Analysis Guidance.

·         In the fourth paragraph of Section 6, removed the words “and signed.”

·         In the fifth paragraph of Section 6, added the institution’s Purchasing Director to those able to approve contracts valued at $150,000-$499,999 and recognized that some institutions utilize the title Vice President instead of Vice Chancellor for Finance and Administration. Also removed the language regarding the institution’s Purchasing Director being able to sign these contracts.

·         In the sixth paragraph of Section 6, added the institution’s Purchasing Director to those able to approve contracts valued over $500,000, recognized that some institutions utilize the title Vice President instead of Vice Chancellor for Finance and Administration, and clarified that these contracts may be (but are no longer required to be) reviewed by legal.

·         In the seventh paragraph of Section 6, clarified that contracts over $1,000,000 with private, profit-making organizations must be approved by the institution’s Purchasing Director and the Vice Chancellor for Finance and Administration. Removed the UW System Office of Procurement from the list of those who must approve and clarified that the campus legal offices at UW-Madison or UW-Milwaukee can review (in addition to the UW System Office of General Counsel). Clarified that RPD 13-1 and RPD 25-4 will define if the contract requires Board of Regents approval (instead of always requiring this approval.

·         In Section 7, added RPD 25-4, Strategic Planning and Large or High-Risk Projects to the list of related documents.


SYS Policy Approval Notification

On November 7, President Jay Rothman approved technical revisions to SYS 825, Special Course Fees.

On November 10, President Rothman approved a new policy, SYS 1038, Information Security: Network Protection.

On November 9, Vice President for Finance and Administration Sean Nelson approved a new procedure, SYS 1038.A, Information Security: Network Protection Standard.

On November 11, President Rothman approved the Vice President for Finance and Administration technical amendment package.

On November 15, President Rothman approved technical revisions to SYS 334, Accountability for Capital Equipment

See below for a brief summary of the policy approvals and revisions.


SYS 825, Special Course Fees

This policy became effective upon approval.

This policy establishes the purposes for which institutions may use special course fees and the procedures for assessing such fees.

·         The policy has been updated to the current policy template, including adding sections for Policy Purpose, Responsible UW System Officer, Scope and Institutional Responsibilities, Definitions, Related Documents, Policy History, and Scheduled Review.

·         Language from Section III, Procedures was integrated into Section 6, Policy Statement of the revised policy with the following changes:

·         In section 6.D, removed duplicative language in the former first sentence.

·         In section 6.E, removed the requirement that institutions must audit special course fees on a regular basis to reflect the fact that not all institutions have internal audit departments.

There were no comments or concerns from campuses during the institutional review period.


SYS 1038, Information Security: Network Protection and SYS 1038.A, Information Security: Network Protection Standard

This policy and procedure will be effective on December 1, 2023.

The purpose of this policy is to provide structure for the deployment and management of network controls used to mitigate Information Security threats throughout the University of Wisconsin (UW) System. This policy was developed with a group of subject matter experts representing multiple institutions across UW System, including UW-Eau Claire, UW-Madison, and UW-Whitewater, as well as UW System Administration. This policy requires:

·         High-level network security architecture documentation be maintained and include high-level security architecture diagram(s).

·         Network access controls be employed to monitor and control communications at external boundaries and key internal managed interfaces, and to protect the integrity and confidentiality of transmitted data.

·         Network IT assets be reasonably secured from unauthorized physical and logical access, and their security-related configuration changes must be documented as part of a defined change management process.

Standards for these policy requirements are further defined in SYS 1038.A, Information Security: Network Protection Standard. Requirements for authentication to network devices and services are defined in SYS 1030, Information Security: Authentication, and are not duplicated in this policy. The standard specifies procedures that require:

·         The high-level network security architecture components that must be included in the documentation and a semiannual review for currency of the documentation.

·         Network access controls that separate networks by trust levels, control the information flow among these trust levels, and address remote access.

·         The standards for cryptography and key management when network controls use cryptographic mechanisms.

·         The standards for network device configuration and secure remote management access.

Institution Comments and Concerns for SYS 1038

·         UW-Madison identified a concern that the documentation requirements were not feasible and requested the requirement be at a higher level of abstraction. The intention of the policy was to be at this higher level of abstraction, and the language in the standard was changed to clarify this intent.

·         UW-River Falls asked to clarify the definitions for Trusted Network Zones and Network Security Zones. These definitions were revised accordingly.

·         UW-Green Bay indicated the term ‘key managed interfaces’ was too vague. A definition for Managed Interface was added, with specification in the policy as to where it applied.

·         UW-Green Bay also identified a concern that the policy prohibited using access control lists (ACLs), which was not the intent. This was addressed through clarifying the Network Zone definition and modifying some terminology in the standard,

Institution Comments and Concerns for SYS 1038.A

·         UW-Madison asked for another round of review because of undefined terms and the large amount of technical detail. In addition to providing clarification and adding definitions, another round of review with subject matter experts from UW-Madison was held.

·         UW-River Falls asked to clarify the definition of Remote Access and associated VPN and split tunnel requirements. The definition for Remote Access was updated with a more specific industry-standard definition. In addition, clarification was provided on clarified split tunnel requirements and where a VPN is required.

·         UW-River Falls asked to clarify the language regarding which network devices applied for the remote management requirements and requested clarification on the requirements on segregated management access. A definition for Managed Interface was added and the remote management language was clarified.

·         UW-Stout asked to clarify a paragraph describing data flows regarding Network Zones. The definitions for Network Zone and Trusted Network Security were clarified to resolve the comment.

·         UW-Superior asked to clarify institution-defined trust levels and the Network Security Zones. The definitions for Network Zone and Trusted Network Security Zone were clarified to resolve the comment.

·         UW-Superior asked to clarify the controls required for inbound and outbound network traffic. The requirement was updated to provide a clearer description.

·         UW-Superior asked to clarify the required remote access services to be disabled on network devices. The requirements were updated to be more specific.


Vice President for Finance and Administration Technical Amendment Package

These revisions became effective upon approval.

On August 31, 2022, UW System President Jay Rothman announced that the Office of Finance and the Office of Administration and UW-Shared Services would be merged into a single Office of Finance and Administration, with the former Vice President for Finance and Vice President for Administration re-designated as the Vice President for Finance and Administration.

To reflect this reorganization, forty-three (43) policies and procedures have been proposed for revision to update seventy-four (74) references to the now-outdated Vice President for Administration, Vice President for Finance, and their respective offices to the Vice President for Finance and Administration and the Office of Finance and Administration.

·         For twelve (12) references, the policy or procedure was updated to instead refer to the Senior Associate Vice President for Finance.

·         SYS 185, College Credit in High School, also contains a reference to the Vice President for Finance in Section 2, Responsible UW System Officer. This reference will be corrected separately from this technical amendment package as part of an upcoming substantive revision to the policy.

No substantive revisions to these policies were proposed as part of these technical amendments.

There were no comments or concerns from campuses during the institutional review period.


SYS 334, Accountability for Capital Equipment

These revisions became effective upon approval.

This policy establishes systemwide parameters for maintain accountability for capital equipment. These include parameters for maintaining an inventory of capital equipment and performing financial reporting and indirect cost calculations, as well as provisions for property purchased either in whole or in part with federal funds.

Technical revisions to his policy have been made to align it with the current UW System Administrative Policy template and the re-numbered State Procurement Manual. These revisions include:

·         In Section 6.B and 7, re-numbered the reference to the State Procurement Manual from PRO-F-1 & 3 to PRO-416.

·         In Sections 6.D and 6.E, re-formatted the numbering scheme to align with the current UW System Administrative Policy template. An internal reference in Section 6.A was revised accordingly.

·         In Section 7:

·         Re-formatted a reference to Wis. Stat. § 36.11.

·         Removed a reference to the now rescinded Regent Policy Document 22-2, Disposal of Works of Art and replaced it with a reference to SYS 335, Deaccessioning of Works of Art and Historical Treasures.

·         Corrected a typo in the reference to 45 CFR Part 74.

There were no comments or concerns from campuses during the Finance and General Administration Policy Committee (FGAPC) review period.


Effective Date Reminder

The revisions to SYS 240, Relocation (Household Moves) and Temporary or Indefinite Work Assignments, which were approved on September 20, 2022, will become effective on January 1, 2023. The newly approved version of the policy can be viewed at SYS 240 Approved and Effective January 1, 2023

Please direct any questions to Michael Kent at mkent@uwsa.edu or Elizabeth Dressel at edressel@uwsa.edu.







 


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