"Policy" v. "procedure"

The question of whether an action by an administrative agency is a "policy" - a quasi-legislative act subject to very limited judicial review and liability - or a "procedure" - an executive act sometimes subject to more judicial scrutiny and perhaps more liability - can be difficult.  There is a quick review in the "board of education" context in "The distinction between policy and procedure" by Jeffrey T. Sultanik (Fox Rothschild LLP, Blue Bell, Pennsylvania). EMM