Behavioral Evaluation and Response Team Policy and Procedures

Philosophy and Scope
Definitions for the Purpose of this Policy and Procedures
Responsible Senior Leader and Responsible Office
Entities Affected by this Policy and Procedures
BERT Composition
Role of BERT Chair
Reporting Behavior of Concern
BERT Response Procedures

I. Philosophy and Scope

Frederick Community College (“FCC” or the “College”) is committed to having a safe environment to ensure the well-being of all students, employees, visitors, and guests. By establishing an effective communication and assessment process, the College community can more effectively respond to student behavior incidents of concern.

Behavioral incidents of concern involving students should be communicated through the Student Behavior Incident Report Form. All reports will be addressed by the Associate Vice President for Student Affairs (AVPSA). In the absence of the AVPSA, BERT will be chaired by a counselor from the Office of Counseling and Wellness Services. The AVPSA will refer all reports involving perceived threats to the safety of the College or community to the College Behavioral Evaluation and Response Team (BERT). Reports of concern for students in distress who are not perceived to be a threat to the College are referred to the Office of Counseling and Wellness Services of the College. The BERT:

makes an appropriate evaluation of student behavior of concern using standardized risk assessment rubrics, such as the National Behavioral Intervention Team Association (NaBITA)
works with the Director of Public Safety to minimize threats and ensure safety
makes recommendations and assigns responsibility in response to behaviors of concern
monitors case progress until closure is recommended
recommends referral to existing College or community services or resources

Cases that fall outside the scope of the BERT will be addressed in accordance with appropriate policies and procedures.

II. Definitions for the Purpose of this Policy and Procedures

“BERT” refers to the Behavioral Evaluation and Response Team and is comprised of College officials who receive and evaluate student and employee concerns regarding student behavior that may be disruptive, or potentially pose a risk of harm to the health, safety, or property of any person or of the College, or otherwise be dangerous.
“College community” refers to trustees, students, and all employees of the College as well as any independent contractors or other third parties to the extent articulated under contractual agreements.
“College official” refers to administrators, supervisors, faculty, adjunct faculty, support staff, campus security, coaches, or trainers.
“Formal assessment” refers to a comprehensive mental health evaluation or medical assessment that results in an evaluative report that is rendered by a licensed mental health or medical provider.
“Risk Assessment Rubric” refers to a tool used to identify the level of risk or threat an individual of concern might pose and provides insight to develop an action plan to address the individual’s behavior with the goal of mitigating or lowering the associated risk.
“Secured College tracking system” refers to the official College system used to record and track reports of student violations of prohibited conduct and concerning behavior. The secured College tracking system contains documentation of reported violations, resolutions, and appeals. The AVPSA is responsible for the oversight and management of reports of student behavior of concern that are assigned to the BERT.
“Student” refers to an individual who is registered at the College, either full or part-time, in a credit or continuing education class or classes, who has either paid or made arrangement for payment of tuition and/or fees.
“Student Behavior Incident Report Form” refers to the form available on the College website and Communication Central which is to be used by College employees to report behavior of concern.

III. Responsible Senior Leader and Responsible Office

Vice President for Student Affairs
Student Affairs

IV. Entities Affected by this Policy and Procedures

The College community

V. BERT Composition

The BERT consists of the following members appointed by the Vice President for Student Affairs: the AVPSA (BERT Chair), the Executive Director of Diversity, Equity, and Inclusion, the Director of Career and Academic Planning Services, the Director of Disability Access Services, the Director of Public Safety, Executive Director of Student Leadership and Engagement, two representatives from Academic Affairs appointed by the Provost, and additional representation from other areas of the College, as needed.

The BERT members are expected to attend regularly scheduled and emergency meetings to discuss BERT cases, provide expertise or background information regarding behavior or concerns reported, and be oriented to the BERT Policy and Procedures and the secured College tracking system. All BERT members will be trained in the use of Risk Assessment standards.

VI. Role of BERT Chair

Arrange and facilitate orientation for new BERT members.
Review cases resulting from Student Behavior Incident Reports as assigned to the BERT by the AVPSA.
Conduct an investigation of the reported concern indicated on the Student Behavior Incident Report Form. The results of the investigation are shared with the BERT once a meeting is convened.
Convene emergency BERT meetings to discuss any reported behavior that is deemed serious in nature and must be addressed immediately for the safety of the student and/or College community.
Communicate any threat or safety concern to appropriate College officials and consult with the Director of Public Safety to determine appropriate notification to the College community.
Convene and facilitate regular meetings to discuss new and open assigned BERT cases.
Document discussion and deliberation notes, updates, and recommendations from BERT meetings in the secured College tracking system.
Update and close cases in the secured College tracking system. Provide necessary updates to the incident reporter and close the case.
Contact the Registrar’s office to apply applicable holds on a student record as necessary.
Notify the Vice President for Student Affairs when assigning a BERT member to serve as designee in Chair’s absence.

VII. Reporting Behavior of Concern

Employee concerns about student behavior should be reported by completing the Student Behavior Incident Report Form. Students who are concerned about the behavior of fellow students should report the concern to any College employee. Behavior may include, but is not limited to: concerns expressed from other students; depressed; disturbed writing; heightened emotional distress; hostile, aggressive or intimidating remarks or behaviors marked change in affect, attendance or academic performance; suicidal remarks or attempts; disturbing social media posts with perceived threats directed toward someone associated with the College; or concerns expressed from others.

For immediate response to a crisis situation and/or a threat to safety, to self, or others that appears imminent, call 911 and Public Safety at 4444 from a main campus phone or a Monroe Center office phone or (301) 846-2453 from any other phone. A Student Behavior Incident Report Form must also be completed after the crisis situation and/or threat has been reported.

Individuals not able to access the Student Behavior Incident Report Form can make a verbal report or send a written report by email to the AVPSA.

All reports will be responded to and, if appropriate, the AVPSA will assign the case to the BERT.

Reports involving potential threats to the safety or security of the College will be communicated to the President or designee and to the Senior Leaders.

Reports involving allegations of Sexual Harassment will be referred to the College Title IX Coordinator.

VIII. BERT Response Procedures

Upon the AVPSA assigning a case to the BERT, the BERT Chair or designee will acknowledge receipt of the report to the originator and provide information about the BERT process and next steps.
The BERT chair or designee will investigate the reported concern, which will include contacting the report's originator for details about the reported behavior and/or any individual named in the report.
The BERT Chair will convene a meeting, if necessary, of the BERT to review the report and information obtained through the investigation. During the meeting, the group will use the NABITA Risk Rubric for a threat assessment based on the report. As appropriate, the individual making the report, or other persons deemed to have relevant information or knowledge of the student and/or the reported behavior may be asked to attend some or all BERT deliberations pertaining to the behavior.
As appropriate, the BERT Chair or BERT may assign one of its members to meet with the reporting individual and/or student who displays behaviors of concern to develop, suggest, or impose strategies to modify or resolve the behavior.
As appropriate, the team may recommend referral to existing College services (e.g., Disability Access Services) or College-sponsored resources (e.g., Career and Academic Planning Services, and Counseling and Wellness Services).
As appropriate, the team may recommend to the AVPSA the implementation of specific College procedures relating to disruptive behavior (i.e., Administrative Withdraw/Referral for Medical and/or Psychological Evaluation).
Reports made to the BERT, deliberations by the team, and recommended response plans will be documented by the BERT Chair in the secured College tracking system. Information will be maintained and disclosed in accordance with College compliance with the Family Educational Rights and Privacy Act (FERPA).
The BERT will continue to monitor behavior and provide status updates in the secured College tracking system until case closure is recommended.
The BERT may recommend consideration of administrative withdrawal of a student to the AVPSA in accordance with Section VII of the Student Withdrawal Policy and Procedures.
1. The identity of the person or persons either filing a report or involved in deliberations will be maintained in confidence by the BERT to the extent reasonably possible.
2. Any person who makes a report in bad faith or in order to intimidate or harass another person under this Policy and Procedures, will be subject to discipline, up to and including dismissal from the College. If a person is found to have deliberately filed a false accusation, they will be subject to disciplinary measures in accordance with the policies and procedures governing student or employee behavior.

In cases where the BERT recommends a formal assessment or an administrative withdrawal that would result in the student incurring a debt to the College, the BERT may recommend that in the interest of preserving the safety of the College community, the debt be written off by the College.