Embedded Files
ADM 18.0
Each Archdiocesan school shall establish a threat assessment team to monitor and respond information about behavior, statements, or plans that may pose a threat (as defined in section 3.0).
1.0 Establishing a Threat Assessment Team
1.1 Each threat assessment team can include persons at the local level with expertise in counseling and/or health, student instruction, and school administration. The principal shall serve as the team leader.
1.2 Each threat assessment team can include persons at the local level with expertise in counseling and/or health, student instruction, and school administration. The principal shall serve as team leader.
1.3 Each threat assessment team shall include a representative from the Superintendent’s office (an Associate Superintendent and/or the Director of Student Support Services).
1.4 In appropriate cases, the threat assessment team may include representatives of the Department of Human Resources, the Office of Risk Management, and/or the Office of Child and Youth Protection.
1.5 The Superintendent may establish a committee charged with oversight of the threat assessment teams.
2.0 Threat Assessment Team Responsibilities
2.1 Provide guidance to faculty, staff, students, and parents/guardians regarding recognition of behavior that may pose a threat.
2.2 Identify to whom threats should be reported. Schools should also instruct students on how to report concerning behavior to the school administration, including providing confidential and anonymous methods for making reports.
2.3 Assess threats and intervene as needed with individuals whose behavior poses a threat.
2.4 In consultation with the Executive Director of Communications and/or legal counsel, as needed, prepare timely notifications to the school community regarding threats.
3.0 Definitions
3.1 A threat is a communication or behavior that indicates intent to cause physical harm, including self-harm, at school or a school activity or to one or more members of the school community. The threat may be expressed by spoken or written words, actions, drawings, electronic communications, or any other means. The threat may be observed by or communicated directly to the target(s) or observed by or communicated to a third party. Threats also may be reported anonymously or through “tips” or rumors. Threats may be direct (“I am going to beat you up”) or indirect (“I’m going to get him”).
3.2 A threat assessment is a fact-finding review process to identify potentially violent situations (including self-harm), assess them, and manage/address them. The goal of the threat assessment process is to maintain a safe and secure school environment.
3.3 Concerning behavior involves actions, statements, communications or responses that are unusual for the person or situation and that cause concern for safety. These can include (but are not limited to):
3.3.1 Unusual social distancing or isolation of subjects from peers and/or family members
3.3.2 Sullen or depressed behavior from an otherwise friendly and positive person
3.3.3 Out of context outbursts of verbal or physical aggression
3.3.4 Increased levels of agitation, frustration and anger
3.3.5 Confrontational, accusatory or blaming behavior
3.3.6 An unusual interest in or fascination with weapons
3.3.7 Fixation on violence as means of addressing a grievance
3.3.8 “Cutting” or other self-injurious actions
3.4 A low risk threat does not appear to pose a threat of serious harm to self or others and any concerns can be resolved easily.
3.5 A moderate risk threat indicates a potential for serious harm to self or others that requires intervention.
3.6 A high risk threat indicates efforts to acquire the capacity to causes serious harm to self or others that requires intervention.
3.7 An imminent threat poses a clear and immediate danger of serious violence towards one or more other persons that requires containment and action to protect any identified or identifiable target(s).
4.0 Procedures
4.1 Anyone who believes that a person or situation poses an imminent threat shall call 911 immediately and take appropriate action to prevent harm in accordance with the school’s emergency response policy.
4.2 All school employees, volunteers, and contractors are required to report any concerning behavior or potential threats to the school principal (or their designee) in a timely manner. Parents must be notified immediately of any threats of self-harm by students.
4.3 The principal may determine that a threat does not exist or that it is a low risk threat that can be handled at the local level. In the case of more serious risks, the principal will convene the threat assessment team.
4.4 The threat assessment team will:
4.4.1 Review the threat.
4.4.2 Review records for any prior history or interventions with the individual(s) involved.
4.4.3 Conduct timely and thorough interviews (as necessary) of the person(s) who reported the threat, the recipient(s) or target(s) of the threat, other witnesses who have knowledge of the threat, and where reasonable, the individual(s) who allegedly engaged in the threatening behavior or communication. The purpose of the interviews is to evaluate the threat in context so that appropriate action can be taken. Two school personnel should be present for each interview and for any reasonable searches of student or staff property or areas under their control (e.g., for weapons).
4.5 The threat assessment team should review the information gathered in a threat assessment in accordance with the questions set forth in Appendix A, as applicable.
5.0 Intervening, Monitoring, and Resolving Threats
5.1 The threat assessment team shall develop, implement, and monitor a plan to address the threat. (See Appendix B regarding possible responses based on the assessment of risk.)
5.2 The team leader (principal) shall maintain documentation of the plan.
5.3 The threat assessment team shall assist affected persons in accessing appropriate school- and community-based resources.
5.4 Where mental health or disability issues are reasonably believed to be causing or contributing to violence risk, and where it is anticipated that the subject will not be withdrawn or expelled (if a student) or terminated (if an employee), a mental health risk assessment should be conducted by a qualified medical/psychological professional. The school may require that the professional conducting the evaluation not have had a treatment relationship with the subject. The assessment should be based on a review of all available information including but not limited to interview of the subject by the professional. The written report should identify the problem or conflict that prompted the threat and recommend strategies to address the problem and to reduce the risk of violence.
5.4.1 The threat assessment team leader will determine the conditions of returning to school that may include the requirement to cooperate in a mental health evaluation. (Note: Under the ADA, any medical examinations or inquiries of current employees must be “job-related and consistent with business necessity.”) If the subject is a student, the parents are to be notified of all requirements and any failure to comply. A meeting must be held prior to the subject’s return to school/work.
5.4.2 Every effort will be made by threat assessment team members to obtain any required signed permission for release and exchange of information with mental health provider(s), if any, and where appropriate, local law enforcement agencies.
5.4.3 After receiving the mental health evaluation report, the threat assessment team shall complete and implement a written Return to School Safety plan to address the immediate steps taken to prevent the threat from being carried out and a plan for further action before the subject is permitted to return to school or an alternative educational environment. The safety plan should include:
5.4.3.1 interventions, such as counseling or medication, that are needed to reduce risk;
5.4.3.2 scheduled follow-up contact with the subject (and parent if subject is a student) to assess changes in risk and update the safety plan over time, until the perceived threat is resolved; and
5.4.3.3 person(s) who are responsible for monitoring and verifying that the safety plan recommendations are being followed.
5.4.4 If the subject poses a significant risk to the health or safety that cannot be eliminated by a minor adjustment of policies, practices, or procedures (i.e., a direct threat), the subject may be removed from school.
5.4.5 If the subject is a student who has a disability, the determination of a direct threat may not be based on generalizations or stereotypes about the effects of a particular disability and must be based on an individualized assessment, based on reasonable judgment relying on current medical evidence or on the best available objective evidence, to determine: the nature, duration, and severity of the risk; the probability that the potential injury will actually occur; and whether minor adjustment of policies, practices, or procedures will mitigate the risk.
5.5 For each case, a member of the threat assessment team shall be designated as a case manager to monitor the implementation of the plan. The case manager provides regular updates to the threat assessment team until the threat is resolved.
5.6 The principal documents the resolution of the threat and closure of the case according to the “Threat Assessment Triage and Assessment Form.” Completed forms should be uploaded into PowerSchool under Incident Management.
6.0 Communication
6.1 In accordance with the guidelines attached as Exhibit B, if appropriate, the principal or designee will promptly notify the intended target(s) and/or subject(s) and their parents or guardians (if students) of the threat. This notification should be made in person or by phone.
6.2 In appropriate cases, the threat assessment team will prepare a timely notification to the school community of the threat and how it has been resolved or is being addressed. Appropriate cases may include:
6.2.1 Cancellations, late arrivals, or early dismissals are required based on the threat
6.2.2 Searches, screenings, security, or other pro-active measures are recommended based on the threat
6.2.3 One or more students, parents, faculty or staff are aware of the threat
6.2.4 The threat is being discussed on social media
6.2.5 Local media outlets (print, radio, television) are aware of the threat
6.2.6 Law enforcement authorities have been seen at the school
6.3 The templates attached as Appendix C may be useful as a starting point for notification to the school community.
7.0 Return to School
7.1 Upon transitioning back to school, a Return to School Safety Plan will be completed for any student who was at a moderate to high/imminent risk and referred for a mental health evaluation.
References:
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