University Behavioral Concerns Team

1. Introduction

The University Behavioral Concerns Team (UBCT or Team) is established to receive, collect, consider, and advise upon information on behaviors of concern exhibited by students, faculty, or staff, or unaffiliated persons on the campus. The Team provides recommendations to University administrators through a multidisciplinary approach centered on a behavior-based assessment process.  The Team is advisory and designed to provide preventive recommendations based on collective analysis related to the following goals:

• Identifying concerning behaviors
• Assess risk of harm to self or others
• Early intervention to reduce risk
• Connect to support and resources

The Team members are selected on their multidisciplinary experience and are trained in threat assessment. Within strict parameters of confidentiality as explained in this regulation, the Team reviews all available relevant evidence, speaks with the individual of concern as appropriate, makes recommendations to affected University departments, and thereby serves as a source of interdisciplinary advice to administrators.
 
Based on training and experience , as well as the serious nature of reported concerns and potential outcomes, assessments and recommendations made by UBCT are intended to be used to inform sound decision making by University administrators. The Team supports all departments and individuals on campus and evaluates whether students, faculty, staff, or other persons of concern have engaged in threatening behavior or have exhibited potentially threatening behaviors that may pose a risk of harm to the campus community, whether the behavior occurred on or off campus. The Team recommends appropriate safety interventions and other assessments to mitigate any risk of harm to the campus community or the individual’s self, and the Team monitors and reviews any ongoing safety interventions.

2. Reporting

Members of the ECU community should report any situation involving a member of the campus community that could result in harm to anyone at the University.

• .1. Threatening Behavior
• Threatening behavior is defined as any communication or action, including action that is the subject of criminal charges, whether occurring on-campus or off-campus, that indicates that an individual may pose a danger to the safety or well-being of any member of the university community, including the individual engaging in the threatening behavior, through acts of violence or other behaviors that may reasonably cause fear of or harm to persons or property or substantially interfere with or disrupt the educational mission of the University. These behaviors may be expressed or communicated orally, visually, in writing, electronically, or through any other means and may be considered threatening regardless of whether a direct threat is expressed or was received by the intended audience or believed by the intended audience.
• 2.2. Imminent Threat
• If such a situation appears to be an imminent threat to safety and security (such as active violence to others) it should be reported immediately to the ECU Police Department by calling 911.
• 2.3. Other Threats
• Any situation of concern not deemed to be imminently dangerous, yet still of concern, should be reported to ECU Cares through the person of concern online reporting form, available at Maxient, or to the UBCT Chair (the UBCT Chair refers to the Director of OVPTM or their designee) at (252) 328-9171.

3. Objective, Process and Resources

• The Team will use investigation, reasoned risk analysis, recognized threat assessment techniques, and recommendations for the provision of supportive intervention services through the development of proposed individual action plans, when needed, to maintain a safe environment for the University community.
• 3.2. Referrals and Intake
• Information about individuals of concern that does not rise to the level of an imminent threat should be forwarded to the UBCT Chair within the Office of Violence Prevention and Threat Management (“OVPTM”) by faculty, staff, and students.
  • 3.2.1. The OVPTM encourages referrals by using the person of concern online reporting form, also referred to as a Cares report, or by phone, email, or in person.
  • 3.2.2. If the Team receives information that is more appropriately addressed and processed by another campus entity, the Team may not conduct an assessment but will forward the information to that entity for review.
• 3.3. Materials and Reports
• In addition to drawing on each Team members’ knowledge, the Team may utilize the opinions and reports of other University personnel or independent outside professionals, such as physicians, licensed psychologists, or psychiatrists, to obtain a better understanding of an individual situation and reports of concern.
  • 3.3.1. Examples of members of the campus community that the Team may seek out for interviews or information include roommates, close friends, family, past and current instructors, coaches, Residence Advisers (RAs), supervisors, and colleagues.
  • 3.3.2 If circumstances warrant, the Team may request permission from the individual of concern to review past medical or psychological records or care providers’ reports as part of its evaluation process.
  • 3.3.3 The Team may recommend independent and/or on-campus medical or psychological assessment by licensed professionals to obtain the most complete information on which to base its recommendations.
  • 3.3.4 The Team may recommend ongoing or interim reports by such professionals as an essential monitoring aspect of the individual action plans.
• 3.4 Procedures
  • 3.4.1 The Team meets regularly throughout the Fall and Spring semesters and as needed in the summer.
    • 3.4.1.1 The Team will also meet on an emergency basis as needed to timely review reports of concerning and/or threatening behavior exhibited by individuals of concern.
  • 3.4.2 Upon receipt of a referral or report about an individual of concern, the Team conducts a risk assessment to determine if it will recommend a finding that the individual poses a threat to the University community. The Team considers:
    • 3.4.2.1 The reported behavior (including any communications about intent to harm or plans for an attack, access to or interest in weapons);
    • 3.4.2.2 The individual’s past behaviors, including history of violence and past disciplinary/behavioral reports;
    • 3.4.2.3 And contributing factors such as: past and ongoing medical or psychological conditions; documented disability; known existing stressors, and if there is an existing support system for the individual, or any other information that may be available to the team and relevant to the review.
  • 3.4.3 Before recommendations are made, UBCT should:
    • 3.4.3.1 Work to collect multiple data points (e.g. reports, observations, academic or employment concerns, social media information, if appropriate);
    • 3.4.3.2 Focus on observable behaviors, not diagnoses or speculation;
    • 3.4.3.3 Identify escalation patterns, stressors or triggering events, access to means, and protective factors; and
    • 3.4.3.4 Assess the intent, capability, imminence, context and past behaviors by using a structured professional model
  • 3.4.4 The Team will determine the level of risk presented by the behavior of concern by assessing the initial report or behaviors of concern, a review of additional corroborating evidence, any other history of concerning behavior, and other relevant information, as deemed appropriate.
  • 3.4.5 Based on the evaluation of the risk and report of concern, the Team may develop a supportive intervention plan with strategies to address the identified level of risk, or it may recommend other approaches including monitoring and engagement, administrative action or other safety actions. An intervention plan will be recommended to appropriate administrators to implement action items, as appropriate. The Team will recommend a plan of action based on its judgment and belief that it is more likely than not:
    • 3.4.5.1 That the recommended plan will have a positive effect on the individual of concern, reducing the threat to the University community; and
    • 3.4.5.2 The plan presents the best available option under the circumstances for both the individual of concern and the greater University community.
  • 3.4.6 When necessary, the Team will use a threat assessment tool to help determine recommendations around safety planning and whether to recommend any interim actions.
  • 3.4.7 Interim Removal from University Property or Programs and Activities
    • 3.4.7.1 Students:
    • The Team will consider recommending interim separations through administrative suspension for students, with the final decision on such separation to be made by the Director of the Office of Student Rights and Responsibilities (OSRR) or designee, where circumstances warrant. If, after an individualized assessment, the Team determines that a student presents an imminent threat to the health or safety of the University community, including the student, the Team may recommend interim separation to remove the student from any or all University property for a temporary time. Such an interim separation is a safety intervention taken to protect the University community and provide the student the opportunity to access resources. It shall be conducted in accordance with the University’s Student Conduct Process (REG11.30.01), and applicable University policy related to administrative suspensions, as applicable.
    • Interim separation shall be presumed to be an appropriate safety intervention when a student has been charged with certain felony criminal offenses, to include any felony offense that involves harm or the threat of harm to persons or property, including assault or the use of violence or force against a person; possession of a weapon on campus or other educational property in violation of N.C.G.S. §14-269.2; communicating a threat of mass violence on educational property in violation of N.C.G.S. 14-277.6; inciting a riot in violation of N.C.G.S. 14-288.2; assault on emergency personnel in violation of N.C.G.S. 14-288.9; any act of terrorism in violation of N.C.G.S. §14-10.1; or other similar felony offenses as defined under applicable law.
    • When interim separation is imposed as an appropriate safety intervention, that determination may be appealed according to any appeal procedure identified by the Student Conduct Process (REG11.30.01) for administrative suspension.
    • 3.4.7.2 Employees: The Team may consider a recommendation for employees engaging in threatening behavior to include placement on investigatory leave with pay or administrative leave with pay. The recommendation may include other interim measures of a non-disciplinary nature (i.e., reassignment) in accordance with UNC System and Office of State Human Resources (OSHR) policies. In addition, the Team may recommend that an employee, when appropriate, be required to undergo an evaluation to determine the extent of any workplace violence risk posed by the employee and their fitness to return to work.
• 3.5 Details of Intervention Plans
• Intervention plans may include, but are not limited to, recommendations such as the following:
  • 3.5.1 Students:
    • 3.5.1.1 Interim Removal from University Property;
    • 3.5.1.2 Campus access restrictions;
    • 3.5.1.3 Interim separations through administrative suspension consistent with 3.4.6.1 of this Regulation;
    • 3.5.1.4 Referrals to resources and appropriate on- and off-campus agencies;
    • 3.5.1.5 Mandates for Center for Counseling and Student Development or external psychological evaluations;
    • 3.5.1.6 Meeting with the Office of Students Rights and Responsibilities or relevant university administrators;
    • 3.5.1.7 Conflict mediation;
    • 3.5.1.8 Wellness check-ins;
    • 3.5.1.9 Peer or faculty mentoring;
    • 3.5.1.10 No contact orders;
    • 3.5.1.11 Residence hall relocations;
    • 3.5.1.12 Class and schedule modifications;
    • 3.5.1.13 Leave of absence or voluntary/involuntary withdrawal; and
    • 3.5.1.14 A timeframe for updates on the progress of the intervention plan as appropriate
  • 3.5.2 Employees:
    • 3.5.2.1 Referrals to resources and appropriate on- and off-campus agencies;
    • 3.5.2.2 Campus access restrictions or relocation;
    • 3.5.2.3 Consultation with the unit administrator or other appropriate supervisor about effective strategies to address the behaviors of concern;
    • 3.5.2.4 Peer or faculty mentoring;
    • 3.5.2.5 No contact orders;
    • 3.5.2.6 Meetings with People Operations, Success, and Opportunity to track progress and ensure implementation of plan;
    • 3.5.2.7 Utilizing available leave options; and
    • 3.5.2.8 A timeframe for updates on the progress of the intervention plan, as appropriate.
    • In no case will an intervention plan prevent University proceedings to continue, including employee misconduct, student misconduct, or academic misconduct proceedings. The appropriate University official responsible for the proceeding will keep the Team apprised of the course of such proceedings, as may reasonably be necessary.
• 3.6 Monitoring and Follow-up
  • 3.6.1 For student behavior, the implementation and outcome of the plan will be coordinated and monitored by the OVPTM Case Manager.
    • 3.6.1.1 The OVPTM Case Manager will monitor and assess time frames and conditions for the return to campus of any student who has been removed from campus as a safety threat, in conjunction with any sanctions imposed under the Student Conduct Process.
  • 3.6.2 For employee behavior, the implementation and outcome of the plan will be coordinated with the appropriate POSO administrator, who will assist the OVPTM Case Manager with advising the appropriate supervisor of the employee of concern.
    • 3.6.2.1 The POSO administrator will monitor and assess time frames and conditions for the return to campus of any employee who has been removed from campus.
    • 3.6.2.2 The plan will be monitored through communication between the supervisor of the employee of concern and, as designated in the plan, either the OVPTM Case Manager or the POSO representative on the Team.
  • 3.6.3 For unaffiliated individual behaviors, the implementation and outcome of the plan would be conducted via community contacts such as law enforcement, along with the OVPTM Case Manager.

4. Confidentiality and Information Sharing.

• 4.1 As a threat assessment and management team, UBCT shall utilize best practices, based on accepted national standards, in evaluating potential threats, and shall have access to student and employee records where necessary and appropriate. Access to student and employee records shall be in compliance with all relevant and applicable state and federal laws, including but not limited to the federal Family Educational Rights and Privacy Act (FERPA), State Human Resources Act, and the Health Insurance Portability and Accountability Act (HIPAA).
• 4.2 Records and information of the Team, consistent with law and University policy, are confidential as provided by law. UBCT shall use standardized documentation and process when conducting its work and must limit the disclosure of information to the minimum information necessary for the purpose of UBCT, as provided by this regulation.
• 4.3 To the extent allowed by and consistent with applicable laws, the Team will have the discretion to determine, on a case-by-case basis who (within the University or external to it) should receive relevant information to better protect the safety of the individual of concern, the University community, and/or others.
• 4.4 The Team may inform an individual of concern of the recommendation to share information or records with others as a necessary condition of an individual action plan, and may seek consent from the individual of concern for adoption of the plan.
• 4.5 All records related to threat assessments conducted by UBCT must be securely maintained and managed in compliance with applicable federal and state laws.
• 4.6 The University will maintain pertinent records related to each case in accordance with the UNC System Records Retention Schedule. Applicable state and federal laws govern access to these records.

5. Available Resources

• 5.1 Students
• The Team is only one of several possible resources available to provide assistance and support for ECU students. Others include, but are not limited to:
  • 5.1.1 the Dean of Students Office;
  • 5.1.2 Disability Support Services;
  • 5.1.3 the Center for Counseling and Student Development;
  • 5.1.4 OSRR;
  • 5.1.5 Student Health Services;
  • 5.1.6 the Pirate Tutoring Center; and
  • 5.1.7 the Academic Advising Center.
  • 5.1.8 Center for Student Success
• 5.2 Faculty and Staff
• The Team is only one of several possible resources that are available to provide assistance and support to ECU employees. Others include, but are not limited to:
  • 5.2.1 The Faculty and Staff Assistance Program, or FASAP, provides mental health services and support in conjunction with standard employee benefits through the State Health Plan. More information about the FASAP can be obtained by contacting the Department for People Operations, Success, and Opportunity. ECU faculty, staff, and their immediate family members can contact the FASAP 24 hours a day, 7 days a week, via Guidance Resources’ toll-free number at 833-743-8183 (or TTY at 800-697-0353), or online at Guidance Resources Online.
  • 5.2.2 ADA Coordinator;
  • 5.2.3 University Ombuds;
  • 5.2.4 Office for Faculty Excellence;
  • 5.2.5 People Operations, Success and Opportunity.

6. Membership

• 6.1. The members of the Team are appointed by the Chancellor and include:
  • 6.1.1Employee Team:
  • • Director for Threat Assessment and Case Management (chair), Campus Safety and Auxiliary Services
  • • ADA Coordinator
  • • Director, POSO Engagement and Development
  • • Senior Director, POSO Success and Opportunity
  • • Assistant Director/Case Manager, Threat Assessment and Case Management
  • • A representative from the Faculty
  • • Public Safety Supervisor, ECU Campus Police
  • • Director, POSO Equal Opportunity and ADA, (Ad-Hoc)Department of People Operations, Success and Opportunity (Ad-Hoc)
  • • Dean of Students (Ad-Hoc)
  • • Associate Vice Chancellor for Campus Safety & Auxiliary Services
  • 6.1.2 Student Team:
  • • Director for Threat Assessment and Case Management (chair), Campus Safety and Auxiliary Services
  • • Dean of Students
  • • Associate Dean of Students, Director of Student Support and Case Management
  • • Director, Center for Counseling & Student Development
  • • Director, Office of Student Rights & Responsibilities
  • • Director, Residence Life
  • • Director, Student Health Services
  • • Director, Office of Disability Support Services
  • • Assistant Director/Case Manager, Threat Assessment and Case Management
  • • A representative from the Faculty
  • • Public Safety Supervisor, ECU Campus Police
  • • Director, POSO Equal Opportunity and ADA (Ad-Hoc)
  • • Department of People Operations, Success and Opportunity (Ad-Hoc)
  • • Associate Vice Chancellor for Campus Safety & Auxiliary Services
  • All members of the team must have experience in their field as related to the Team’s purpose, maintain confidentiality and ethical standards, and complete threat assessment training from an approved provider. Threat assessment training must be completed within 90 calendar days of joining the team.
• 6.2 Faculty members serving on the team will be determined by the Chancellor, after consultation with the Chair of the Faculty.
• 6.3 Representative(s) from the Office of University Counsel will serve in an advisory capacity and will provide legal guidance to the Team.
• 6.4 UBCT members must attend annual training to stay informed and up to date on industry trends. The Chair shall track attendance at these annual trainings to ensure compliance.