Bellingham Public Schools
3225 Policy – School-Based Threat Assessment
3225 Policy – School-Based Threat Assessment
Bellingham Public Schools 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. The district will not impose suspension or expulsion, including emergency removal, solely for investigating student behavior 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 removal, if the district has sufficient cause to believe that a 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 will establish and ensure the training of a multidisciplinary, multiagency threat assessment team to serve district schools. The threat assessment team must include Special Education teachers and practicing educational staff associates, such as a school counselor, school psychologist or school social worker. The threat assessment team may also include school administrators, other district or school staff, community partners in law enforcement and other individuals from community resources, as necessary.
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/guardians and the student in the resolution of the student’s behavioral violations consistent with Policy 3241 Student Discipline
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 federal Family Educational Rights and Privacy Act (FERPA). No member of a threat assessment team, including district or school-based members and community resource or law enforcement members, will 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:
A. Identifies and assesses the behavior of a student who 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 2145 Suicide Prevention.
B. 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 and criminal history records. The purpose of obtaining information is to evaluate situational variables rather than the student’s demographic or personal characteristics.
C. 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 will make an individualized assessment, based on reasonable judgment, best available objective evidence and/or current medical evidence as applicable.
D. 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.
F. 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 unless appropriate.
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 Section 504 plan team, school-based threat assessments remain distinct from those teams and processes.
Data Collection, Review and Reporting
The superintendent will establish procedures for collecting and submitting data related to the school-based threat assessment program that comply with the office of superintendent of public instruction (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:
A. Providing guidance to students and staff regarding recognition of behavior that may represent a threat to students, staff, school, the community or the individual.
B. Providing informational resources for community services boards or health care providers for medical evaluation or treatment, as appropriate.
Cross References:
Policy 2121 - Substance Abuse Program
Policy 2145 - Suicide Prevention
Policy 2161 - Special Education and Related Services for Eligible Students
Policy 2162 - Education of Students with Disabilities Under Section 504 of the Rehabilitation Act of 1973
Policy 3143 - Notification and Dissemination of Information about Student Offenses and Notification of Threats of Violence or Harm
Policy 3231 - Student Records
Policy 3241 - Student Discipline
Policy 3432 - Emergencies
Policy 4210 - Regulation of Dangerous Weapons on School Premises
Policy 4310 - District Relationships with Law Enforcement and Other Government Agencies
Legal References:
CFR 34, Part 99, Family Educational Rights and Privacy Act Regulations
Management Resources:
Policy News, October 2021 Protecting Student Journalism
Policy News, August 2001 A Few Civil Liberty Reminders
Policy News, May 2018 Freedom of Expression in Student Journalism
Policy News, July 2015 Recent Federal Ruling Basis for Freedom of Expression Update
Adopted: 1/3/23
Revised: 1/4/24
Superintendent or Board Approved: Superintendent Approved
- Series 3000