The Massachusetts school drew up the draft in the wake of the tragic suicide by the 15-year-old Irish student.
Phoebe hung herself Jan. 14 after what prosecutors described as "relentless" bullying at school.
The new policy requires all South Hadley staff members to report "any bullying they see or learn about" and pledges to "promptly and reasonably" investigate any claims of bullying.
The draft says the definition of bullying means causing "physical or emotional harm," putting students in "reasonable fear of harm" or creating an "unwelcoming or hostile environment at school for another person."
School officials have been blasted for not doing more to protect the young Irish immigrant.
The six former students at South Hadley who face felony charges over her death have all pleaded not guilty.
The new draft from the school specifically defines bullying in the following way:
Severe or repeated use by other students of written, verbal or electronic communication or physical acts or gestures which cause physical or emotional harm, create a hostile environment, infringe on the person’s rights or disrupt the educational process.
Well that sounds about right but why did it take them so long to do it?
If they had created this policy earlier Phoebe might still be alive.