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WVU-PD-7

WVU-PD-7 Threat Assessment, Behavioral Intervention and Suicide Prevention Policy

1. PURPOSE & SCOPE.

1.1. Purpose.  This Policy is designed to mitigate and diminish risk to members of the University community through a coordinated team approach by assessing and managing imminent threats, ongoing potential threats, behavior that requires immediate intervention, and behavior that requires ongoing and follow up interventions.

1.2. Scope.  Applies to all incidents occurring or affecting the members of the University community.

2. THREAT ASSESSMENT COORDINATION TEAM.

2.1. General.  The University shall have a Threat Assessment and Coordination Team (“TACT”) comprised of various members needed to respond effectively to Direct Threats. TACT is a means to assess the potential of threatening and violent behavior at West Virginia University and to intervene and address such conduct. Successful intervention into incidents of threatening and violent behavior is dependent upon an immediate and coordinated assessment of each individual situation. TACT shall respond to reports of potential threats to campus, lead inquiries and investigations into reported threats and individuals of concern and employ strategies to reduce risk of harm to members of the WVU community. There will be Core Members as well as Situational Members depending on the nature of the threat. All members, regardless of whether Core or Situational, should be familiar with TACT policies and procedures.

2.2. TACT Membership. 

2.2.1.  Core Members. These members will be on all TACT calls and should include a member of the University Police Department (UPD), General Counsel’s Office, and President’s Office.  

2.2.1.1. Roles The Chair of the TACT will be the Chief of Police or designee. UPD will coordinate meetings, implement emergency safety and law enforcement measures as needed, provide coordination with other local law enforcement agencies, and direct and coordinate, to the extent possible, any direct action needed by the University to address the threat. The General Counsel’s Office will provide legal advice and expertise on risk management and applicable laws, including privacy laws. The President’s Office will take, or direct the appropriate units or individual to take, necessary action to implement any necessary interventions requiring University action.

2.2.2.  Situational Members Those members of the TACT that may be necessary depending on the potential threat, as decided by the Chair of the TACT.

•  Threats Involving Students. For threats primarily involving students, the following members may also be involved, as necessary: Carruth Center for Psychological and Psychiatric Counseling; Dean of Students; Office of Student Conduct; Residence Life; the CARE Team Coordinator; an Academic Representative from the Student’s Department, Provost’s Office, or, if a Health Sciences Center (HSC) student is involved, a member from HSC or other designee; and any other individual at the Chair’s discretion in consultation with other Core Members.

•  Threats Involving Faculty. For threats primarily involving faculty, the following members may also be involved, as necessary: Provost’s Office; Employee Relations; Faculty Staff Assistance Program; a Representative from the Faculty Member’s Department or College; and any other individual at the Chair’s discretion in consultation with other Core Members.

•  Threats Involving Staff. For threats primarily involving staff, the following members may also be involved, as necessary: Employee Relations, Faculty Staff Assistance Program, a Representative from the Employee’s Department, likely from management; and any other individual at the Chair’s discretion in consultation with other Core Members.

• In all cases, including cases that may not fit into the categories mentioned above, Core Members will convene and may involve other entities as necessary, including Facilities, Information Technology, Internal Audit, Ruby Emergency Management, Environmental Health and Safety, local law enforcement or other outside agencies as warranted under the circumstances and at the Chair’s discretion in consultation with other Core Members.

2.3. TACT Communication. Consistent with the Emergency Notification and Timely Warning requirements of the Clery Act and implementing regulations, as well as any other alert UPD deems necessary, TACT will update University Relations regarding any potential mass communication that may need to be sent, which will be done in accordance with the applicable protocols.

2.4.  TACT Training. All Core Members should be trained in threat assessment coordination at a minimum of every two years. It is the responsibility of the Core Members to also train and update Situational Members as necessary regarding protocols and expectations.

2.5.  TACT Reporting. The primary mode of reporting people or situations of concern is through the University Police Department Dispatch (304-293-2677). The Dispatch Officers will refer the necessary information and provide written documentation of the concern to the TACT Chair or designee for immediate review and determination of TACT activation. This includes assessment for the need of immediate police response, which takes precedent for imminent safety concerns and TACT is activated after the immediate threat is mitigated.  Individuals or situations assessed at an elevated or higher level according to the applicable assessment tool should be referred to the TACT Chair for further assessment.

2.6.  TACT Assessment & Interventions. TACT will utilize a standardized risk rubric for evaluating situations that have potential for violence as well as utilizing structured professional judgment. TACT will utilize the NaBITA Risk Rubric, the SIVRA-35 (Structured Interview for Violence Risk Assessment), and/or forensic psychological evaluations as necessary.

2.6.1. Failure of an individual to participate in a mandated assessment will result in appropriate action being taken, including potential charges under the Campus Student Conduct Code or discipline for insubordination for an employee.

2.6.2.  Following any assessment, TACT will identify and implement any necessary interventions in order to mitigate the potential threat.    

2.7. Conflict with UPD Internal Policies. To the extent this policy is inconsistent with UPD internal policies, such as the Active Shooter Policy or the Bomb Threat Policy, those policies will govern and all efforts should be taken to protect the University community irrespective of any technical language contained in this Policy.

2.8. TACT Meetings.

2.8.1.  Activation Meetings. TACT response is activated by the Chair in consultation with Core Members and meetings will occur on an as needed basis as potential Direct Threats are reported. The TACT Chair will contact appropriate members to put them on notice that TACT has been activated.  A referral or other administrative form should be included so that members can properly research and provide information at the meeting time. Each meeting will follow a set agenda. For example, if circumstances allow, there should be roll call; statement of facts (from the report); presentation of facts from team members; assessment/triage questions; determination of intervention(s) and completion timeframe; and plan to reconvene, if necessary.

2.8.2. Administrative Meetings. TACT will hold annual administrative meetings to review efficacy of the team and interventions, trends or other concerns, and engage in training.

2.8.3. Critical Incident Debriefing Meetings. As determined by the Chair and when necessary, the TACT should meet following the initiation of a TACT call to debrief regarding the University’s response to an incident.

2.9. TACT Documentation, Confidentiality, and Reporting.

2.9.1.  TACT records will be maintained by the Chair and records of meetings will be documented to the extent practical.

2.9.2.  All information that is gathered by the TACT including decisions and actions is confidential and should not be disclosed outside of TACT, excluding “duty to warn” information that must be disclosed to manage risk situations, and other information necessary to conduct business on behalf of the TACT. Documentation of TACT meetings regarding risk situations and resulting recommendations and proposed courses of action or interim and final reports summarizing TACT decisions are deliberative in nature and not subject to disclosure unless required by law.

3. SUICIDE PREVENTION & CRITICAL RESPONSE.

3.1.  General . In order to further the goals of W. Va. Code §18B-1B-7 (Jamie’s Law) and the Resolution to Approve the Development and Implementation of a Plan to Advise Students, Staff, and Incoming Students on Suicide Prevention Programs and Resources Available On and Off Campus , which was adopted on June 5, 2015, the University shall continue to take steps to monitor and provide resources to the University community regarding suicide and other issues requiring critical response that face the University community. This includes programming, outreach, and a protocol to handle such situations.

3.2.  Programming . At least once annually, members of Student Life, Talent & Culture, the Provost’s Office, the Faculty Staff Assistance Program, Carruth Center for Psychological and Psychiatric Counseling, and WVU Medicine will meet and review programming and, at a minimum, develop a programming schedule to address the various members of the University community, and meet the requirements of W. Va. Code §18B-1B-7 (Jamie’s Law). This group will be chaired by the Dean of Students or designee.

3.3.  Outreach . At least once annually, the Division of Student Life and Talent and Culture will communicate to students (including incoming students), faculty, and staff about the available suicide prevention programs on and off campus. Additionally, websites devoted to suicide prevention shall be monitored and updated regularly, including:

3.3.1.  Carruth Center for Psychological and Psychiatric Services, https://carruth.wvu.edu/

3.3.2. WVU Faculty and Staff Assistance Programs,  https://www.hsc.wvu.edu/fsap/home/

3.4.  Protocol.

3.4.1.  The University shall develop a crisis response protocol for suicidal members of the University community.

3.4.2.  The Division of Student Life and Talent and Culture will communicate to Campus Security Authorities and Responsible Employees before the beginning of the Fall and Spring semester a protocol to initiate should an individual face a potential crisis.

         3.5.  Training.

3.5.1.  Those individuals who are likely to be in contact with students, faculty, or staff requiring immediate assistance through a critical response or suicide prevention protocol shall be trained regularly, including faculty and unique customer service positions.

3.5.2.  Training documentation should be kept with other student, faculty, or staff training records.

4. STUDENT BEHAVIOR INTERVENTION/CARE TEAM.

4.1. Purpose & Scope.

4.1.1.  The University shall have a multidisciplinary student behavioral intervention group that addresses and helps at-risk students obtain the needed support and assistance to be successful at West Virginia University, which will be known as the CARE Team.

4.1.2.  The CARE Team, through a collaborative and proactive approach is committed to identifying, preventing, assessing, intervening, and reducing threats to the safety and well-being of students and the greater WVU community.

4.1.3.  The CARE Team directly serves all WVU students of concern, including graduate and professional students, and the WVU community indirectly by way of consultation, training, and management of student concerns.

4.1.4.  The CARE Team, however, is not an immediate crisis response team. Thus, any immediate concerns should be addressed to relevant emergency service, e.g . 911, University Police Department, Carruth Center for Psychological and Psychiatric Services, Title IX hotline.

4.1.5.  The CARE Team is an administrative and consultative body that works collaboratively with on- and off- campus units to resolve student concerns.  Activation of the CARE Team for a student concern does not absolve units from their functional duties.

4.1.6  CARE is not a disciplinary body; however, the Team may engage and/or assist other units including the Office of Student Conduct, University and other police agencies, and/or academic departments.

4.2. CARE Membership. The Chair of the CARE Team will be from the Campus and Community Life Department or designee. To that end, membership is determined by Chair and periodically evaluated for utility but should include the following: 

4.2.1.  Core Members . These members will be in regular meeting attendance and should include a member of Campus and Community Life, Carruth Center for Psychological and Psychiatric Services, Office of Student Conduct, University Police Department, Housing and Residence Life, Division of Diversity, Equity and Inclusion, Center for Learning, Advising, and Student Success, Provost’s Office, and CARE Case Management.

4.2.2.  Situational Members . Those members of the CARE Team that may be necessary depending on the potential student situation or presentation, as decided by the Chair of CARE.

4.3. CARE Training. All Core Members should be trained in Threat Assessment Coordination at a minimum of every two years. It is the responsibility of the Core Members to also train and update Situational Members as necessary regarding protocols and expectations.

4.4. CARE Reporting. The primary mode of reporting people or situations of concern is through the CARE Team Public Reporting Form, available on the CARE Team website.  CARE referrals should be submitted for students who are exhibiting a concerning observed behavior as listed on website and referral form.  If a potential reporter has a concern that is not on the outlined concern list, they should contact the Office of Campus and Community Life for guidance (304-293-5611). CARE referral submissions are reviewed during standard University operating hours.

4.5. CARE Assessment. CARE will utilize a standardized risk rubric for evaluating situations that have potential for violence as well as utilizing structured professional judgment.  CARE will utilize the NaBITA Risk Rubric, the SIVRA-35 (Structured Interview for Violence Risk Assessment), and/or forensic psychological evaluations as necessary.

4.5.1.  When appropriate, the CARE Team may require a student to take a risk assessment.

4.5.2.  Although CARE will not impose discipline itself, failure of an individual to participate in a mandated assessment will result in appropriate action being taken, including potential charges under the Campus Student Conduct Code

4.5.3.  CARE Team members shall have access to appropriate and necessary information and databases to properly assess student situations and conduct interventions.

4.5.4. Individuals assessed at an elevated or higher level on hostility and violence towards others according to the NaBITA Risk Rubric scale will be referred to the TACT Chair for further assessment.  

4.6.  CARE Interventions. Following assessment, CARE will identify and implement any necessary interventions in order to reduce risk to the student and/or community and promote student success. CARE will also engage in follow up monitoring of student behavior.

4.7.  Documentation and Confidentiality.

4.7.1.  CARE records will be maintained by the Chair and documented to the extent practical.

4.7.2.  The CARE Team operates under Family Educational Rights and Privacy Act (FERPA) unless a more restrictive level of confidentiality or disclosure requirement pertains to a CARE Team member such as law, licensure requirement, or professional ethical policy or regulation. Accordingly, CARE records will be maintained and will only be disclosed consistent with FERPA or as required by law.

4.7.3.  Individuals performing their roles as members of the Team are school officials with legitimate educational interest in educational records for the purpose of FERPA.

4.7.4. CARE Team may utilize another unit to perform an intervention based on the student of concern relationship to that unit, nature of the concern and student needs.  In those instances, limitations on shared information are determined and expectations for the interaction and subsequent documentation are shared with the unit/individual performing intervention.  Student of concern membership with a group or unit does not in itself justify full or partial disclosure of referred student information.

4.7.5. Consistent with FERPA and the University’s FERPA notice, certain disclosures may be necessary. More information can be found here:  https://ferpa.wvu.edu/explanation-of-rights .

4.7.5.1.  Of particular note, consistent with FERPA, disclosures may occur to parents of a student regarding the student’s violation of any federal, state, or local law, or of any rule or policy of the school, governing the use or possession of alcohol or a controlled substance if the school determines the student committed a disciplinary violation and the student is under the age of 21. Similarly, disclosures may be appropriate to appropriate officials in connection with a health or safety emergency consistent with FERPA.

5. EMPLOYEE FACULTY STAFF ASSISTANCE PROGRAM & FITNESS FOR DUTY.

5.1.  The University will have a Faculty Staff Assistance Program (FSAP), which is a free service offered to employees and their dependents. FSAP is a resource that provides professional staff and a safe place to discuss problems and determine the best resources available to address them. All employees, particularly supervisors, should encourage employees to utilize FSAP as needed. More information can be found here: https://www.hsc.wvu.edu/fsap/

5.2.  In addition to the FSAP, the University has also developed a fitness for duty policy, which can be found here:  https://talentandculture.wvu.edu/employee-relations/fitness-for-duty-guidelines

6. DEFINITIONS.

6.1.  “Direct Threat” – unambiguous statement to a target or to authorities of intent to do harm or inflict injury or damage to that target or others.

6.2.  “UPD” refers to the University Police Department.

6.3.  “President” means the President of the University or the President’s designee.

6.4.  “Student” has the same definition as WVU BOG Student Life R. 6.1 – Student Rights and Responsibilities; Student Conduct. 

7. DISCRETION AND EFFICIENT ADMINISTRATION; SUPERSEDING PROVISIONS.

7.1.  To the extent not already expressly stated in this Policy, the President or designee shall have sufficient latitude and authority to implement any reasonable measures necessary for the fair and efficient administration of this Policy. Minor deviations from this Policy are acceptable as long as those deviations are not materially harmful to the purpose of the Policy.

7.2.  Given that this is a new policy, this Policy does not supersede and replace any other specific policy.

8. AUTHORITY.

8.1.  WVU BOG Finance and Administration Rule 5.3 – Emergency Management and Campus Safety; WVU UPD General Order 054 (Bomb Threats and Searches); WVU UPD General Order 15-0072 (Clery Act Data Collection); WVU UPD General Order 12-0103 (Active Shooter).

8.2.  W. Va. Code §18B-1B-7 (Jamie’s Law); Resolution to Approve the Development and Implementation of a Plan to Advise Students, Staff, and Incoming Students on Suicide Prevention Programs and Resources Available On and Off Campus , WVU Board of Governors (June 5, 2015).

Office of the Vice President for Strategic Initiatives