POL - 10.07.2 NCCU Threat Assessment & Management Team Policy

1. Purpose

North Carolina Central University (NCCU) is dedicated to maintaining a safe and secure environment where students, faculty, and staff can learn, teach, work, and contribute to the University's mission and goals. This policy establishes a framework for timely and effective interventions for individuals within the NCCU community who may pose credible or potential threats of harm to others or who may disrupt the University’s lawful activities and educational processes. The requirements of this policy are facilitated by the Threat Assessment and Management Team (TAMT).

2. Scope

This policy applies to all members of the North Carolina Central University (NCCU) community, including students, faculty, staff, and visitors. It governs the processes and procedures related to identifying, assessing, and managing potential and actual threats to the safety and security of the campus community. The policy encompasses all behaviors and actions, whether occurring on- campus or off-campus, that may pose a risk to individuals or disrupt the University's educational mission. This policy is applicable in all situations where there is a concern for the well-being of a member of the University community and may be implemented in conjunction with other relevant University policies and legal requirements.

3. Definitions

3.1  Threatening Behavior: Any communication or action, including actions that are the subject of criminal charges, whether occurring on-campus or off-campus, that indicates an individual may pose a danger to the safety or well-being of any university community member. This includes actions that may cause fear, harm to persons or property, or disrupt the educational mission of the University. Such behavior may be communicated through any means and may be considered threatening even if no direct threat was expressed or received by the intended audience.

3.2  NaBITA Threat Assessment Tool: NCCU adopts the National Behavioral Intervention Team Association (NaBITA) Threat Assessment Tool to categorize and evaluate behaviors based on risk levels. This tool provides a framework for understanding and responding to varying levels of risk, from mild to extreme. The tool classifies behaviors into categories such as distress, disturbance, dysregulation, and dangerousness, which inform the TAMT's intervention strategies.

4. Threat Assessment and Management Team (TAMT)

4.1 Mission: The Threat Assessment and Management Team (TAMT) is a multidisciplinary team appointed by the Chancellor, tasked with assessing and establishing interventions for individuals in the University community who pose potential or actual threats of harm to others. Additionally, the TAMT oversees the review and ongoing monitoring of these safety interventions.

4.2 Team Members: The Threat Assessment and Management Team includes but is not limited to, personnel from the following departments:

• Office of the Dean of Students – Dean of Students
• Law Enforcement – Chief of Police or Designee
• Student Conduct and Community Standards - Director
• Human Resources – Director of Employee Relations and Affirmative Action
• Counseling Services - Director
• Residential Life – Associate Director
• Office of General Counsel– Assistant University Legal Counsel
• An active graduate, undergraduate and law student.
• Office of the Chancellor – Chief of Staff/Vice Chancellor

4.2.1  Legal Guidance: The Office of General Counsel shall provide legal guidance to the TAMT in conducting threat assessments and implementing safety interventions.

4.2.2  Review of the membership of the TAMT will be conducted at least annually.

5. Procedures for Threat Assessment

5.1  In conducting the threat assessment review, the TAMT may consider any information deemed relevant to protect the safety of the campus community, including information regarding threatening behavior both on and off campus.

5.2  Threat assessments are snapshots in time, meaning that changes in circumstances or the emergence of new information can lead to different outcomes at different assessment points. The TAMT will follow established protocols to appropriately assess any threats based on the information available at that time of assessment.

5.3  Procedures of the threat assessment process are outlined in the Threat Assessment Protocol document.

6. Recommendations

6.1 Upon the completion of a threat assessment review, the Threat Assessment and Management Team (TAMT) at North Carolina Central University (NCCU) will recommend appropriate safety interventions to the relevant administrator who has the authority to implement these recommendations. These safety interventions are not disciplinary in nature but are intended to mitigate any identified risks to the safety and well-being of the campus community or the individual involved.

The TAMT may recommend a range of interventions, including, but not limited to, the development of an individualized case management plan, voluntary withdrawal or extended leave, involuntary withdrawal or extended leave, or interim removal from campus. All recommended interventions will prioritize the safety of the campus community including the individual whose actions are being assessed. The Chancellor retains the discretion to modify or change the recommended interventions, subject to legal limitations.

In situations where an individual poses an imminent threat to health or safety of any member of the University community, interim removal from university property may be recommended. Such emergency interventions can be enacted using expedited procedures when deemed necessary by the TAMT. For employees, this may involve investigatory or administrative leave. For students, interim separation may include temporary removal from university premises. Interim separations are considered safety measures and are not a penalty or a disciplinary action.

Interim separation may be enacted by the appropriate administrator upon the recommendation of the threat assessment and management team as part of the safety intervention process, or by the chancellor in their sole discretion based on the chancellor’s review of the evidence considered by the threat assessment and management team. Interim separation shall be presumed to be an appropriate safety intervention when a student has been charged with certain felony criminal offenses. Nothing in this regulation supersedes or amends NCCU’s disciplinary proceedings under the University’s student code of conduct or other behavioral or disciplinary codes or regulations.

When the TAMT determines that interim separation is an appropriate safety intervention, that determination may be appealable to the chancellor, and the decision of the chancellor shall be final. If the chancellor independently imposes interim separation based on their review of the evidence considered by the threat assessment team, then the chancellor’s decision shall be final.

After implementing the appropriate interventions, the TAMT will continue to monitor the individual’s situation to ensure that necessary resources are provided and will periodically reassess the need and appropriateness of the safety interventions, including assessing the time frames and conditions for the return to campus of any person temporarily removed. This ongoing monitoring ensures that the safety of the NCCU community is maintained and that interventions remain effective as circumstances evolve.

7. Reporting Threats

7.1  Imminent Threats. Anyone who has information to indicate that an imminent threat exists should contact University Police immediately. The police will respond appropriately to maintain a safe and secure campus based on the facts presented. The Threat Assessment and Management Team will be notified and called together as soon as possible, if needed.

​​​​​​​7.2  Non-Imminent Threats: If a concern is deemed not immediate, an individual shall report the threat to University Police, the Department of Human Resources (if the threat involves an employee), and/or the Threat Assessment and Management Team reporting form linked here.

8. Training

TAMT members shall receive annual training on best practices for threat assessment, confidentiality, and relevant laws and policies. Records of training programs will be maintained within the data management system.

9. Records Retention

North Carolina Central University (NCCU) requires that all records related to threat assessments conducted by the Threat Assessment and Management Team (TAMT) be securely maintained and managed in compliance with applicable federal and state laws, including the Family Educational Rights and Privacy Act (FERPA), the Health Insurance Portability and Accountability Act (HIPAA), and the State Human Resources Act (SHRA).

All documentation, including assessment findings, recommendations, communications, and any related notes, shall be retained for a minimum of three years from the date of the final assessment or resolution of the case. If a case is reopened or additional information is added, the retention period will restart from the most recent date of activity.