Policies & Procedures

Miscellaneous

SIUE Threat Assessment Policy - 2C12 & 3C13

1. Purpose
   
   

   This policy is created to set forth the manner and method under which the SIUE Threat Assessment Team shall operate to assess and address issues relating to potential and pending acts or threats of violence at SIUE.   The Threat Assessment Team exists as an additional resource, in addition to other University administrative staff and resources, to review and assess actual cases and/or incidents within the University community in which a potential or actual threat of violence is present.  At SIUE, the Behavioral Intervention Team (BIT) serves as the University’s “Threat Assessment Team”.

2. Behavioral Intervention Team
   
   

   1. Purpose:  The purpose of the BIT is to review and assess actual cases and/or incidents involving potential or actual threats of violence (to self or others) in order to determine whether a threat of violence or actual violence is probable and/or imminent.  The Behavioral Intervention Team shall work in conjunction with the Conduct, Assessment, and Intervention Team (CAIT), the Campus Violence Prevention Committee and other University departments to review, address, and respond to issues of potential violence or threat within the University community.

   2. Responsibilities:   The Behavioral Intervention Team is responsible for receiving and reviewing information obtained from a reporting party, witness or observer in order to determine whether a threat is present.  Additional responsibilities include reviewing incident reports, police reports and/or complaints of threats to self or others, or actual violence, reviewing patterns or practices which indicate a potential for violence, and investigating and assisting other University officials or representatives in dealing with serious threats and/or incidents of violence.  The Behavioral Intervention Team is not intended to address workplace issues, such as, performance behavioral matters that are regularly handled by the Offices of Human Resources or student misconduct that is regularly handled by the Office of the Vice Chancellor for Student Affairs.   The Team shall:

      1. Assess, review and analyze incidents involving potential or imminent danger or violence to determine if a threat of violence is present.  This may include but not be limited to creating detailed and fact-based assessments of students, employees, or other individuals who may present a threat to themselves or to the University community;
      2. Work with the affected unit to develop and implement an appropriate action plan to alleviate repercussions of incidents of violence and to prevent future incidents;
      3. Conduct an investigation and any necessary follow-up as appropriate;
      4. Provide information and make recommendations to appropriate University functional units for appropriate corrective action or assistance to prevent future incidents of violence;
      5. Support the Campus Violence Prevention Plan and the Campus Violence Prevention Committee by creating a campus-wide threat assessment policy, conducting threat assessments, and addressing aberrant, dangerous, or threatening behavior on campus;
      6. Assist the University community to the extent possible with anticipating and responding to future acts of violence; 
      7. Support University personnel by providing direct communication, education, and guidelines about University expectations and to insure that anyone who poses a threat is given explicit feedback about their behavior and detailed expectations about future behavior.
3. Authority
   
   

   The Threat Assessment Team, known at SIUE as the Behavioral Intervention Team (BIT), was developed pursuant to the Illinois Campus Security Enhancement Act (110 ILCS 12/1 et. seq.)  The Team will adhere to all University, local, State and Federal statutes, including the Illinois Mental Health and Developmental Disabilities Confidentiality Act (740 ILCS 110/1 et. seq.), FERPA, and the Americans with Disabilities Act of 1990 (ADA), among other State and Federal laws.

4. Members of the Behavioral Intervention Team
   
   
   1. Provost and Vice Chancellor for Academic Affairs Designee
   2. Chief of Staff, Chancellor's Office
   3. Director of Counseling Services
   4. Associate Director of Counseling Services
   5. Senior Associate General Counsel
   6. Director of Human Resources
   7. Dean of Students and/or Designee
   8. Chief of University Police
   9. Associate Director, University Housing

     * Consultation occurs with other offices and/or departments as needed.

All members of the Behavioral Intervention Team are expected to attend training(s) and maintain current knowledge in the areas of threat assessment procedures, appropriate handling of students/employees with mental illness or those who pose a threat to self or others, and other related areas, as would be necessary for the performance of their team related campus responsibilities.

1. General Procedures
   
   Chair:  The Associate Director of Counseling Services will chair both the regularly scheduled and ad hoc meetings of the Behavioral Intervention Team. In the Chair’s absence, he or she shall designate a team member to act on his or her behalf. The Team will maintain a roster of active cases.  At each regularly scheduled meeting, the Team will review and discuss cases, both past and present. 
   
   Action Required:  When the Behavioral Intervention Team is notified of an incident, the appropriate team members will confer as soon as reasonably possible to determine what response, if any, is necessary. If the Behavioral Intervention Team determines that a threat is present, the Team shall inform the proper University officials or representatives to initiate prompt, reasonable and remedial action, as necessary.  The Team will meet on a regular basis and as needed.
   
   Assessment of Cases:  The Behavioral Assessment Team will be responsible for overseeing all cases that have initiated an assessment based on the designated threat categories with specific team members assigned to handle specific cases and/or aspects of cases.  The Behavioral Assessment Team will coordinate with the appropriate University administrators and offices regarding plans and recommendations based upon the assessment. The Behavioral Assessment Team will also track the student/individual's response to any recommendations and to the behavioral expectations that have been established.  
   
   There are five threat behaviors that will activate the Behavioral Assessment Team:
   
   
   1. The individual makes a threat of violence towards a specified person(s), including themselves or the community as a whole.  The threat might be direct or indirect, implicit or explicit, veiled or outright, but leaves a reasonable observer in fear of his or her safety.  The threat might take the form of verbal or written statements and/or might occur through various electronic media.
   2. The individual engages in “significant suicidal or homicidal ideation” that is alarming and disturbing to a reasonable observer and is divorced from any significant artistic intent.
   3. An individual assumes a stance of being substantially “in charge” of processes or outcomes, or decisions and movements of another person, that is inappropriate given his or her standing or position.
   4. An individual persists in pursuing options and outcomes that do not reasonably exist after being instructed to cease pursuing them, continues to do so in an unreasonable manner.
   5. An individual appears to be suffering from a delusion, the context of which either requires him or her to be violent or increases the likelihood that he or she will use violence to protect him/her from the perceived violence of others or becomes a danger to himself/herself.
2. Case Management
   
   

   Case Managers – All non-counseling services members of the Behavioral Intervention Team will serve as Case Managers. The Dean of Students will serve as the Lead Case Manager given that this individual has necessary authority without the responsibility of maintaining privileged information the way mental health professionals do. During Behavioral Intervention Team meetings, the team will collaboratively determine which Case Manager is responsible for managing specific cases. The Team will also determine appropriate interventions for Case Managers to use.

   
   Timeliness – Any meetings with a student/individual will occur as soon as reasonably possible—preferably that same day or the day after, depending upon the nature of the situation.  Ideally, the first round of meetings will occur within five business days of the receipt of the report and no later than one calendar week.  Depending upon the circumstances of a particular situation, availability of the parties and/or their representatives, or other relevant factors, the scheduling of such meetings can take longer.
   
   Written expectations – One of the goals of the Team is to provide students/individuals who pose a threat with clear and explicit expectations regarding future behavior.  The Behavioral Intervention Team, working through regularly scheduled meetings, ad hoc meetings and/or the team listserv, will determine who will draft a letter of expectations and/or follow-up with the individual, as needed.   As appropriate, in the context of one of the meetings with the student/individual or shortly thereafter, the student/individual will be provided with a letter outlining the reported behavior, the University's concern, the University's expectations regarding future behavior, and the consequences of future occurrences of similar behavior. In as much as possible written correspondence will be provided at the time of the meeting, however, it may become necessary to deliver correspondence prior to or after a scheduled meeting.  To the extent that the student/individual adheres to the specified limits, the University's response remains consistent.  In the event that a student/individual violates the limits, it will result in further reports, additional sanctions and/or increasingly restrictive limits up to and including criminal arrest, separation or other appropriate disciplinary action, pursuant to University policies and procedures.
   
   Recordkeeping – Each member of the Behavioral Intervention Team will have access to a database software program on a secure server.  The Behavioral Intervention Team will maintain the secure database of students/individuals under active consideration, as well as the initial report and actions taken to date.  Each Behavorial Intervention Team member will be responsible for maintaining records in accordance with their established practices, University policy, and in compliance with State and Federal privacy and records laws.
3. Case Threat Level Classifications
   
   Cases will be classified in accordance with the following levels.
   
   Inactive Status- No Risk- Person/situation does not appear to pose a threat of violence or self-harm at this time, nor is there evidence of significant disruption to the community.  This category also includes students/employees who are no longer affiliated with the University, and thus cannot be monitored. The team can close the case without a management or monitoring plan, following appropriate documentation. Individuals placed on Inactive Status will remain a part of this record and can be moved back to Active Status if deemed appropriate.
   
   Priority 1- Low Risk- Person/situation does not appear to pose a threat of violence or self–harm at this time, nor is there evidence of significant disruption to the community.  The case may warrant some intervention, referral and monitoring to minimize rise for escalation to threat. The Team should develop a monitoring plan. Monitoring Plan: Assigned Case Manager will follow up with the individual twice a semester to monitor risk/safety. Follow up with the individual must be either face to face, by phone, or email (whichever the Team deems to be appropriate).
   
   Priority 2- Moderate Risk- Person/situation does not appear to pose a threat of violence or self-harm at this time, but does exhibit behaviors/circumstances that may escalate and to be disruptive to the community. The case may warrant some intervention. The Team should develop a monitoring plan. Monitoring Plan: Assigned Case Manager will follow up with the individual monthly to monitor risk/safety. Follow up with the individual must be either face to face, by phone, or email (whichever the Team deems to be appropriate).
   
   Priority 3- High Risk- Person/situation appears to pose a threat of self-harm or physical violence, usually to an identifiable target, but currently lacks immediacy and/or a specific plan or a specified plan of violence does exist but currently lacks a specific target. This requires the Team to develop and implement a management plan. Monitoring Plan: Assigned Case Manager will follow up with the individual biweekly to monitor risk/safety. Follow up withe the individual must be either face to face, by phone, or email (whichever the Team deems to be appropriate).
   
   Active Threat- Person/situation appears to pose a clear and immediate threat of serious violence toward self or others and requires containment. The Team should immediately notify law enforcement to pursue containment options and take actions to protect identified targets. Once such emergency actions have taken place the Team shall then develop and implement a management plan in anticipation of the person’s release or return to campus.
4. Reporting Procedures
   
   
   1. Imminent Danger or Threat:  If the circumstance(s) indicate(s) imminent danger to persons or damage to property the individual will implement the following actions, in order:
      
      
      1. Notify the University Police immediately (911 or 618-650-3324);
      2. If you are an employee notify your immediate supervisor or the Office of Human Resources at 618-650-2190; if you are a student worker or graduate assistant notify your immediate supervisor or the Dean of Students at 618-650-2020; if you are a student notify the Dean of Students at 618-650-2020.
   2. Non-Imminent Danger or Threat:  An individual witnessing or experiencing threats, threatening behavior, or acts of violence against faculty, staff, students, visitors, or other individuals covered by this policy will take the following action if the circumstance(s) does not indicate an imminent danger to persons or damage to property.
      
      
      1. If you are not an employee or a student, please report the incident to the University Police at 618-650-3324 or 911.
      2. If you are an employee notify your immediate supervisor or the Office of Human Resources at 618-650-2190; if you are a student worker or a graduate assistant notify your supervisor or the Dean of Students at 618-650-2020; if you are a student please report the incident to the Dean of Students or another University administrator.
      3. Individuals may file a Care report at Counseling .  Please note that Care Reports are NOT monitored 24/7. If you are hoping for an immediate response, please call University Police at 650-3324 or 911.
5. Applicability
   
   The Threat Assessment Policy applies to all SIUE facilities, property, faculty, staff, students, visitors, and others at the University. In as much as University policies and procedures may not apply to non-University affiliated persons outside of University property, the threat protocols can be used to assess the threat of non-University persons with appropriate criminal and/or “no trespass” sanctions applied. It is the responsibility of all faculty, staff, and students to familiarize themselves and to comply with this Policy and its procedures and any related policies and procedures. Related policies and procedures include but are not limited to the Campus Violence Prevention Plan, the Student Conduct Code or the applicable employee personnel policies at Administrative/Professional Staff, Civil Service, or Faculty.    

Approved by Chancellor effective 10/19/18.
This policy was issued on June 27, 2014.
Document References: 2C12 & 3C13
Origin: OC 4/30/14