The Board is committed to providing a safe and secure learning environment for students and staff. This policy establishes a school-based threat assessment program to provide for timely and methodical school-based threat assessment and management.

Threat assessment best occurs in school climates of safety, respect, and emotional support. Student behavior rather than a student’s demographic or personal characteristics will serve as the basis for a school-based threat assessment.

The threat assessment process is distinct from student discipline procedures. The mere fact that the district is conducting a threat assessment does not by itself necessitate suspension or expulsion and the district will not impose suspension or expulsion, including emergency expulsion, solely for investigating student conduct or conducting a threat assessment. Further, suspension, or other removal from the school environment can create the risk of triggering either an immediate or a delayed violent response, unless such actions are coupled with containment and support. However, nothing in this policy precludes district personnel from acting immediately to address an imminent threat, including imposing an emergency expulsion, if the district has sufficient cause to believe that the student’s presence poses an immediate and continuing danger to other students or school personnel or an immediate and continuing threat of material and substantial disruption of the educational process.

Structure of Threat Assessment Teams

The superintendent or designee shall establish and ensure the training of a multidisciplinary, school-based, threat assessment team for each school. As the threat assessment team must be multidisciplinary and it might include persons with expertise in: 

• Counseling, such as a school counselor, a school psychologist and/or school social worker,
• Safety and Security Department representation,
• School administration, such as a principal or other senior administrator,
• Other district or school staff, such as PBIS/MTSS team members
• Community resources (as appropriate),
• Special education case managers (if the student is being evaluated for, or has an IEP), and a
• School staff with knowledge of the student and/or the incident

Not every multidisciplinary team member need participate in every threat assessment, except the school administrator, who is a required participant. 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. This does not diminish the district’s commitment that school personnel will make every reasonable attempt to involve parents and the student in the resolution of the student’s behavioral violations, consistent with Policy and Procedure 3241 – Student Conduct.

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. Every member of the team is required to sign a Confidentiality Agreement prior to receiving any student information, or participating on a team. Non-district employees are required to sign a Non-Disclosure Agreement. 

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 according to Policy 2120 – Suicide Prevention.
• 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. Throughout this process, team members should check their own implicit biases, as well as the team reflecting on any collective implicit biases;
• 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.

Data Collection, Review and Reporting

The superintendent or designee shall establish procedures for collecting and submitting data related to the school-based threat assessment program that comply with OSPI’s monitoring requirements, processes, and guidelines.  

Other tasks of 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 general information on community resources as needed; 
• Providing informational resources for community services boards or health care providers for medical evaluation or treatment, as appropriate.

District Cross Reference:
Substance Abuse Program- Policy 2121
Suicide Prevention- Policy 2120
Special Education and Related Services for Eligible Students- Policy 2161
Education of Students with Disabilities under Section 504 of the Rehabilitation Act of 1973- Policy 2162
Notification and Dissemination of Information about Student Offenses and Notification of Threats of Violence or Harm- Policy 3143
Student Records- Policy 3250
Student Discipline- Policy 3240
Regulation of Dangerous Weapons on School Premises- Policy 4316
District Relationships with Law Enforcement and other Government Agencies- Policy 4411
Notification of Threats of Violence or Harm- Policy 4314

WSSDA Cross References:
Notification of Threats of Violence or Harm  - Policy & Procedure 4314/4314P
Bid or Request for Proposal Requirements Procedure- Procedure 6220P
School-Based Threat Assessment- Policy & Procedure 3225/3225P

Legal Reference:
CFR 34, Part 99, Family Educational Rights and Privacy Act Regulations
Chapter 28A.320 RCW
Chapter 28A.300 RCW
 

Highline School District 401
Adopted by the Board: November 2020
Classification: Essential