Risk Assessment Policy and Procedures

Effective Date:

August 1, 2024

Office of Primary Responsibility

Dean of Students Office

SECTION 1

Purpose: The procedures described below establish a process for safety intervention and involuntary withdrawal of students who pose a credible substantial risk of harm to individuals within the College or to the College community, or substantially impede the lawful activities, educational processes, or proper activities or functions of other members of the College community.

NOTE: If you believe a student is at imminent risk of harming self or others, please contact Public Safety at 814-332-3357 or contact the emergency services at 911

Policy:

 Allegheny College prohibits threats and acts which pose a credible substantial risk of harm to individuals within the College or to the College community, or substantially impede the lawful activities, educational processes, or proper activities or functions of other members of the College community on college property, within college facilities, at any college-sponsored event, while engaged in any college educational or athletic activities, or while traveling on college sponsored and/or related business. This includes, but is not limited to:

• Engaging in behavior that creates a reasonable fear of injury to self, others, or property. 
• Engaging in behavior that would subject a reasonable person to extreme emotional distress.
• Engaging in behaviors that could significantly impact the ability of others to participate in educational activities. 
• Causing injury to a person or persons (including oneself).
• Threatening to injure self, others, or property.
• Possessing, brandishing, or using a weapon while on College property and/or during College related activities; or threatening to use a weapon towards a community member and/or College property. 
• Retaliating against any employee or student who, in good faith, reports a violation of this policy.

Student conduct, judicial, academic or other proceedings may continue even when a student is subject to an intervention or involuntary withdrawal pursuant to this policy.

Consequences of Policy Violation(s):

1. Students who violate the above policy will be subject to disciplinary action as outlined in the Student Handbook. In addition, students who may be identified as posing a risk to the campus community may be referred to the Risk Assessment and Intervention Team (RAIT)  (see Section 2). 
2. At times, the Risk Assessment and Intervention Team may determine that individuals pose a significant risk to the safety of the campus community and, as a result of that determination, may have safety measures put in place, up to and including removal from campus. (See Section 2).

Definitions: 

• Threatening Behavior: includes harming, abusing, assaulting, threatening, endangering, intimidating, stalking, or harassing another person and extends to all oral or written statements, communications, conduct, gestures, expressions, or acts made in any medium (e.g., in person, via letter, telephone, text message, electronic mail, social media, or any other method) that causes a reasonable apprehension of physical or emotional harm to another person.
• Risk Assessment: An individualized assessment that includes an investigation of a threat, potential threat, or perceived threat towards an individual (including self), group, and/or property, as well as an examination, survey, and consideration of the behavior patterns, conditions, circumstances, and variables of danger in or surrounding an individual or group (Van Dreal, 2017). This can include, but is not limited to:
  • Mental or Medical Health Evaluation (if relevant)
  • Review of written materials such as emails, social media posts, texts messages
  • Conversations with faculty/staff/advisors
  • Any relevant surveillance materials such as camera footage and card access
• Risk Assessment Intervention Team (RAIT): A committee consisting of the following individuals: Dean for Student Life (Chair), Director of Public Safety, Dean of Diversity, Equity, and Inclusion, and Title IX Coordinator who assess potential risks and threats, and determine appropriate responses. These committee members have all been trained in threat/risk assessment practices. Additional members of the community may be asked to participate as part of the RAIT, including, but not limited to mental health professionals, Human Resources, and others as appropriate. Members of the committee may be asked to recuse themselves by the Chair of the RAIT if there is a conflict of interest.
• Preventive Measures: The College may exclude a student from or place special conditions on a student’s participation in College programs or activities if the RAIT concludes that the student poses a direct threat, meaning the student poses a high probability of substantial harm to the health and safety of self and/or others. These measures include, but are not limited to:
  • No Contact Orders
  • Housing relocation
  • Restrictions from certain places/activities
  • Removal from campus
• In instances where there is not adequate time to convene the RAIT, the Director of Public Safety and/or the Dean for Student Life may implement an immediate preventive measure until a time that the RAIT is able to convene.

SECTION 2

Practices:

The following is an outline of standard practices for the RAIT. At times, the RAIT may need to deviate from the following, but in those instances, will document the reasoning for the deviation.
 

Reporting of Potential Threat(s)/Risk(s):

Any person who believes that there is an imminent or immediate threat to the campus community, should contact Public Safety at 814-332-3357, or call the emergency services at 911. All reports made pursuant to this policy will be handled in a confidential manner, with information released only on a need-to-know basis in accordance with applicable federal and state laws and regulations.

Reports of Potential Threat(s)/Risk(s) are also made in the following ways:

• Incident Reports
• Residence Life Reports
• Academic Reports
• Bias Incident Reports
• Title IX reports
• Written or verbal communication with administration, faculty, students, or family.

Initial Meeting:

When a potential Risk/Threat has been identified, the Chair of the RAIT will convene the RAIT as soon as possible. (These meetings generally occur virtually). The team discusses the potential risk and decides if it rises to the level of a full risk assessment, and, if so, are there any necessary preventive measures that need to be put in place to help ensure the safety of the campus community, as well as any required documentation to be provided by the student.

*For individuals removed from campus as an preventive measure regarding the Harassment, Discrimination and Sexual Misconduct Policy, see Part 2 of the Harassment, Discrimination and Sexual Misconduct Policy; section Emergency Removal for information regarding the individual’s right to appeal. 

Student Notification:

If the RAIT identifies the need to raise to the level of a Risk Assessment, the student will be notified in writing (sent electronically). The student will be notified of the potential risk that is being assessed, the risk assessment process, a timeline for providing documentation/statements/etc., and preventive measures that will be put into place (if applicable). The notification will also contain resources available to the student if they are experiencing any distress related to the Risk Assessment process. 

Risk Assessment:

Upon student notification, the following will occur:

• Compilation of materials: the Chair of the RAIT will compile relevant materials to complete the assessment, including but not limited to:
  • Previous conduct record
  • Any incident reports related to the perceived risk(s)
  • Relevant card access data and/or camera footage
  • Relevant information from faculty/coaches/advisors
  • Documentation submitted by the student, including any required documentation (such as Mental Health Evaluation) and any statement the student wishes to include.
  • As part of this individualized assessment, the student may be required to undergo an evaluation, including a medical or psychological evaluation, by an independent and objective health professional designated by the College. The student may also be required to execute necessary releases so that the report from the evaluation may be provided to the RAIT, and other administrators if appropriate, for the purposes of determining whether the student should be subject to an intervention or involuntary withdrawal.
    • The College will not require a student to provide a comprehensive mental health evaluation and/or similar documentation, except for:
      • In the course of conducting an individualized assessment of whether that student poses a direct threat to the health and safety of others, when it has a reasonable basis to believe that the student may pose such a threat; or
      • As otherwise reasonably necessary for the College to comply with its obligations under section 504 of the Rehabilitation Act. 
• The Chair will reconvene the RAIT and review the documentation and the details of the perceived risk(s). 
  • When appropriate, in making the assessment, the College will confer with individuals who have in-depth knowledge of, and experience in, the disability. Pending the outcome of a formal assessment, the College may set interim conditions on the student, provided the student is afforded minimal due process. 
• Where the College has a reasonable basis for believing that a student poses a direct threat, and the risk of harm to others is not imminent (i.e., not a situation the College deems to be an emergency), it will make an individualized assessment of the direct threat posed by the student, based on a reasonable judgment that relies on current medical knowledge or on the best available objective evidence, to ascertain: 
  • The nature, timing, and severity of the risk; 
  • The probability that the potential injury or significant harm will actually occur; and 
  • Whether reasonable modifications of the College’s policies, practices, or procedures will mitigate the risk.
• Inherent to this decision-making process is the College’s commitment to consider an individual’s past and ongoing condition, which may have contributed to the risk of harm that is in question. The RAIT may seek the assistance of other resources, as needed, to determine if the student is a qualified individual with a disability and whether a reasonable accommodation will allow that student to meet his/her essential academic and College community responsibilities, while abating the risk of harm and maintaining a safe college environment for all students. This determination shall also evaluate whether such accommodation can be provided without fundamentally altering the essential functions of the educational program provided by the College, or lowering academic standards, and/or creating undue hardship to the College.
• Moreover, whether or not the student is a qualified individual with a disability, the RAIT or designee will generally attempt to engage in an interactive dialogue with the student to discuss the manner in which the student plans to abate the risk of harm presented by the student. As part of this interactive process, the student and/or his medical provider are encouraged to suggest possible methods to abate the risk of harm, and the RAIT or designee will generally actively seek the student’s suggestions. The RAIT or designee and student may also choose to engage professionals or College administrators in formulating a proposed plan. The RAIT may then determine if the proposed plan devised as a result of the interactive dialogue appropriately addresses the risk of harm that formed the basis for the decision to intervene with or involuntarily withdraw the student. If the RAIT finds the proposed plan is inappropriate or insufficient to address the risk of harm, the RAIT or designee may resume the interactive process with the student.
• If the College determines that a student does not pose a direct threat to the health and safety of others, or determines that the student no longer poses such a direct threat, the College will not exclude the student from or place special conditions on the student’s participation in its programs or activities, and as such, provide the proper written notice to the student of this determination, effectively readmitting the student and restoring all their attendant privileges, benefits and services, as a student in the College’s academic program in the status of, and at the academic level attained by the student prior to the determination that the student was a direct threat. 

Findings:

The student will be notified of the findings of the RAIT in writing (sent electronically) and any requirements put in place by the RAIT. This document will include an explanation of how the RAIT arrived at its findings.  This document will also include any applicable timeline, and reasonings for any requirements put into place. These findings could include (but not limited to) the following:

• No Contact Orders
• Housing relocation
• Restrictions from certain places/activities
• Removal from campus

Documentation:

All documentation related to the Risk Assessment process will be stored electronically in a case file in Maxient (conduct software). Students may request copies of the documentation by contacting the Dean for Student Life. Risk Assessments, as well as the process and policy will be reviewed on a biennial basis. 

If a student is subject to an intervention or is involuntarily withdrawn pursuant to this policy, to the extent appropriate and practicable, conditions for readmission may be specified in writing by the RAIT or designee

If the College determines that a student poses a direct threat, the College may condition the student’s future receipt of a benefit or service upon the student’s provision of documentation showing that the student is no longer a threat. Such evidence may include, but not be limited to, a treatment plan or periodic reports from a physician. The College will not, however, condition the provision of a benefit or service upon a showing by a student that they have eliminated behaviors that are a manifestation of a disability, unless such behavior significantly contributed to the direct threat.