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4350P - School-Based Threat Assessment Procedure

Procedure 4350P

COMMUNITY RELATIONS

Structure of Threat Assessment Teams

The superintendent will designate an administrator to establish and ensure the training of a multidisciplinary, multiagency threat assessment team or more than one such team to serve district schools. Teams should include persons with expertise in: 
•    Counseling, such as a school counselor, a school psychologist and/or school social worker,  
•    Law enforcement, such as a school resource officer,  
•    School administration, such as a principal or other senior administrator,  
•    Other district or school staff, 
•    Community resources, 
•    Special education teachers, and a 
•    Practicing educational staff member.  

Not every multidisciplinary team member need participate in every threat assessment. When faced with a potential threat by, or directed towards, a student receiving special education services, the threat assessment team must include a team member who is a special education teacher. 
  
Although parents, guardians, or family members are often interviewed as part of the threat assessment process, neither the student nor the student’s family members are part of the threat assessment team.  

Function of Threat Assessment Team 
Each threat assessment team member, whether a teacher, counselor, school administrator, other school staff, contractor, consultant, volunteer, or other individual, functions as a “school official with a legitimate educational interest” in educational records controlled and maintained by the district. The district provides the threat assessment team access to educational records as specified by the Family Educational Rights and Privacy Act (FERPA). No member of a threat assessment team, including district/school-based members and community resource/law enforcement members, shall use any student record beyond the prescribed purpose of the threat assessment team or re-disclose records obtained by being a member of the threat assessment team, except as permitted by FERPA. 
  
The threat assessment team: 

•    Identifies and assesses the behavior of a student that is threatening, or potentially threatening, to self, other students, staff, school visitors, or school property. Threats of self-harm or suicide unaccompanied by threats of harm to others should be promptly evaluated. 
•    Gathers and analyzes information about the student’s behavior to determine a level of concern for the threat. The threat assessment team may conduct interviews 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 individual’s threat in context to determine the meaning of the threat and intent of the individual. The threat assessment team may request and obtain records in the district’s possession, including student education, health records, and criminal history record information. The purpose of obtaining information is to evaluate situational variables, rather than the student’s demographic or personal characteristics. 
•    Determines the nature, duration, and level of severity of the risk and whether reasonable modifications of policies, practices, or procedures will mitigate the risk. The threat assessment team will not base a determination of threat on generalizations or stereotypes. Rather, the threat assessment team makes an individualized assessment, based on reasonable judgment, best available objective evidence, or current medical evidence as applicable
•    Communicates lawfully and ethically with each other, school administrators, and other school staff who have a need-to-know particular information to support the safety and well-being of the school, its students, and its staff; and 
•    Timely reports its determination to the superintendent or designee. 

Depending on the level of concern determined, the threat assessment team develops and implements intervention strategies to manage the student’s behavior in ways that promote a safe, supportive teaching, and learning environment, without excluding the student from the school. 
  
In cases where the student whose behavior is threatening or potentially threatening also has a disability, the threat assessment team aligns intervention strategies with the student’s individualized education program (IEP) or the student’s plan developed under section 504 of the rehabilitation act of 1973 (section 504 plan) by coordinating with the student’s IEP team or section 504 plan team. Although some of the functions of a school-based threat assessment may run parallel to the functions of a student’s IEP team or 504 plan team, school-based threat assessments remain distinct from those teams and processes. 

Records, Data Collection, Review, and Reporting 
The district will collect and submit data related to the school-based threat assessment program to comply with OSPI’s monitoring requirements, processes, and guidelines. 

Records, reports, plans, and other documents generated through the threat assessment protocol will be stored in a confidential file apart from the cumulative file. Said documents shall be maintained at the school and the Student Services Office and may only be released pursuant to a subpoena or other valid court or administrative order. Threat assessment documents may also be transferred to the regional Threat Assessment Coordinator, a receiving school district, or a receiving school within Pasco School District. Threat assessment documents are confidential and would not be released to parents or guardians in a student records request except when required by a court or administrative order.
  
Other Tasks of the Threat Assessment Team 
The threat assessment team may also participate in other tasks that manage or reduce threatening or potentially threatening behavior and increase physical and psychological safety. This may include: 
•    Providing guidance to students and staff regarding recognition of behavior that may represent a threat to students, staff, school, the community, or the individua and 
•    Providing informational resources for community services boards or health care providers for medical evaluation or treatment, as appropriate. 

Notification of Threats of Violence or Harm
Staff, students, volunteers, and others involved in school activities have the responsibility to report any threats of violence or harm to designated school officials. Based on the significance and credibility of the threat, it shall be reported to law enforcement. Staff shall involve in- district multi-disciplinary professionals in evaluating the threat and the needs of the person making the threat. Consultation with or referrals to community-based professionals and services are encouraged where appropriate.

Under the Family Educational Rights and Privacy Act the district may only release student records, including those involving threats of violence or harm, with parent or adult student permission, or under limited conditions. For that reason, the district will not identify students who have made threats of violence or harm when notifying the subject of the threats, except under the following conditions:

A.    The parent or adult student has given permission to disclose the student’s identity or other information to the subject of the student’s threat.

B.    The identity of the student and the details of the threat are being disclosed to relevant district staff who have been determined to have legitimate educational interest in the information.

C.    The identity of the student or the details of the threat are being released because the release of the information is necessary to protect the health or safety of the student or other individuals. This exemption is to be strictly construed pursuant to federal regulations.

D.    The district is responding to a court order or subpoena. Generally, the district must make a reasonable effort to notify the parents of the student or adult student of the subpoena in advance of complying, so that the family can seek protective action.

Relevant information about the threat that does not improperly identify a student shall be provided to the subject of the threat, and the subject shall be advised that if law enforcement has been involved in the matter, the law enforcement agency may have more information that can be shared with the subject.

To promote the safety of all concerned, the principal shall determine if classroom teachers, school staff, school security, and others working with the student(s) involved in the threat circumstance should be notified. Subject to the confidentiality provisions cited above, the principal shall consider all information when determining the extent of information to be shared, including prior disciplinary records, official juvenile court records, and documented history of violence of the person who made the threat.

When considering the appropriate discipline for a student who has made a threat of violence or harm, the student’s prior disciplinary records shall be taken into account. Emergency expulsion shall be considered, based on the credibility and significance of the threat. Discipline shall only be imposed on students with disabilities consistent with policy and the legal requirements for special education.

If the threat by a student was significant and credible enough to warrant expulsion, the student may only be readmitted to the district through the readmission application process provided for in district policy. The readmission application process shall include meeting district readmission criteria established at the time of expulsion and should include completion of an assessment by an appropriate professional with a report to the district, when the district determines such an assessment is necessary.

District staff found to have made threats of violence or harm shall be subject to disciplinary action, up to and including termination of employment. Discipline against district staff for making threats of violence or harm shall be consistent with district policy and procedure regarding staff discipline, and any relevant collective bargaining requirements.

Adoption Date:     August 23, 2023