This policy becomes effective January 1, 2024 and replaces the prior version of this policy:

I. Definitions:

a) Assessment: the identification of individuals exhibiting threatening or other concerning behavior.

b) Concerning Behavior: An observable behavior that elicits concern in others regarding the safety of an individual or those around them. Important to determining whether behavior is concerning is whether it deviates from the person's baseline behavior. Some concerning behavior for one person may be "normal" behavior for another person. Concerning behavior is a spectrum that can include lower-level concerns, such as unusual interests in violent topics, conflicts or grievances between classmates, increased anger, increased substance use, or other noteworthy changes in behavior (e.g., depression or withdrawal from social activities), and prohibited behaviors that are objectively concerning and should trigger an immediate response, such as threats, weapons violations, and other aggressive or violent behaviors.

c) Concerning Communication: Unusual, bizarre, threatening, or violent communications made by an individual or group. Concerning communications may include explicit threats or allude to violent intentions; violence as a means to solve a problem; justification of violent acts; unusual interest in weapons; personal grievances; or other inappropriate interests. Concerning communications may be expressed verbally, visually, in writing, electronically, or through other means. Concerning communications may be considered threatening, even if they do not involve a direct and explicit threat of violence. Concerning communications may also allude to hopelessness or suicide.

d) Education Records: Any records or documents, including information derived from those records or documents, that are directly related to a student and are maintained by an educational agency or institution, or by a party acting for the agency or institution. 34 C.F.R. s. 99.3. In most cases, this includes student health and mental health records maintained by an educational agency or institution. Law enforcement unit records, as defined by 34 C.F.R. ss. 99.3 and 99.8, are not considered education records.

e) Florida Harm Prevention and Threat Management Model or Florida Model: The Florida-specific behavioral threat management process required by Section 1001.212(12), F.S. The Florida Model consists of the Florida Threat Management Manual and the Florida Harm Prevention and Threat Management Instrument (“Instrument”).

f) Imminent Threat: An imminent threat exists when a situation, including the person's prohibited objective behavior, poses a clear and immediate threat of serious violence toward self or others that requires containment and immediate action to protect an identified or identifiable target.

g) Level of Concern: The classification of an individual is based on their presenting risk and needs and balanced against protective factors. Levels of concern (also called threat levels) are classified as Low, Medium, or High:

1. Low Level of Concern: A Low level of concern designation is appropriate where a person poses a threat of violence or exhibits other concerning behavior that is minimal and it appears that any underlying issues can be resolved easily. This level means the concern for future violence toward another person is low. There may nonetheless be significant concerns about the person but at that time, the concern for violence toward another is at the low end of the spectrum.

2. Medium Level of Concern: A Medium level of concern designation is appropriate where the person does not appear to pose an immediate threat of violence, but the person exhibits behaviors that indicate a potential intent to harm or exhibits other concerning behavior that requires intervention. This level suggests that violence toward another may occur, and although the situation is not urgent, violence cannot be ruled out. The threat management team may not have complete or completely accurate information to guide the outcome of the assessment.

3. High Level of Concern: A High level of concern designation is appropriate where the person poses a threat of violence, exhibits behaviors that indicate both a continuing intent to harm and an effort to acquire the capacity to carry out a plan, and may also exhibit other concerning behavior that requires immediate intervention and protective measures for the target. This level suggests the student of concern is reaching a critical point on the pathway to violence from which they perceive it may be difficult to turn back. A High level of concern requires immediate and continuing attention from threat management 

h) Reasonable effort to notify: The exercise of reasonable diligence and care to make contact with the student’s parent or guardian, typically through the contact information shared by the parent or guardian with the school or school district. The SBTMT Chair or designee must document all attempts to make contact with the parent or guardian.

i) Student of Concern: Any student reported to the Chair, Vice Chair, SBTMT or DTMT who exhibits any behavior or communication that may constitute a threat or concern regarding school safety.

j) Student Support Management Plan or SSMP: An ongoing intervention and monitoring plan implemented by the school-based threat management team. The SSMP may impose requirements on a student of concern for a defined period of time based on the level of concern. The SSMP is reviewed each month by the School Based Threat Management Team (SBTMT). The Student Support Management Plan (SSMP) uses direct and indirect interventions to help create an environment less likely to produce violence. The SSMP is implemented by the threat management team imposing requirements on the student. Under the SSMP, a student of concern may be required to refrain from certain conduct or may be required to engage in certain actions that are designed to prevent harm to others. The SSMP is established for a specified period based on the level of concern and is reviewed each month by the School-Based Threat Management Team (SBTMT).

k) Threat: A threat is communication or behavior indicating that an individual poses a danger to the safety of school staff or students through acts of violence or other behavior that would cause harm to self or others. A threat includes communication or behavior characteristic of a person who is on the pathway to violence. The threat may be expressed or communicated behaviorally, orally, visually, in writing, electronically, or through any other means. Communication or behavior is considered a threat regardless of whether it is observed by or communicated to the target of the threat, or to a third party, and regardless of whether the target of the threat is aware of the threat.A threat is not a communication or behavior that is an obvious joke or unequivocally known by the observer to be innocuous. The school personnel's personal knowledge of the person making the statement or exhibiting the behavior, as well as the person's age and history of exhibiting such behaviors or making such statements, are factors that should be considered in determining whether the communication or behavior constitutes an actual threat.

I) Threat Assessment Protocols: Threat assessment protocols are used to assess concerning behavior and threats. Threat assessment protocols are a series of documents, also referred to as a "threat assessment instrument," comprised of an intake and disposition form; student of concern questionnaire; parent/guardian questionnaire; witness/target of violence questionnaire; teacher survey; and mental health assessments used to help evaluate whether behaviors or communications indicate that a student poses a risk of harm and what services are appropriate to mitigate that risk. The threat assessment process results in comprehensive information gathering from multidisciplinary sources, including law enforcement, mental health, and school records.

m) Threat Management: The multipart process by which schools identify individuals exhibiting threatening or other concerning behavior that poses a threat to the safety of the school, school staff, or students, assess the risk of harm, and coordinate appropriate interventions and services for such individuals.

The threat management process is a systematic, fact-based method designed to identify, using threat assessment protocols, whether behaviors or communications constitute a concern for violence or harm to another person. Upon a determination that a risk of violence exists, the threat management process then results in determining the level of concern and appropriate management of the person posing the concern to mitigate the risk of harm and remove them from the pathway to violence. The SSMP is part of the threat management process. The threat management process is ongoing and ends only when the threat management team deems it appropriate under the circumstances, or responsibility is transferred to another threat management team.

1. Threat management is not a means to profile the next school shooter. There is no profile of a school shooter or student attacker. The threat management process focuses on behavior-based prevention, not a prediction. Because a student has been the subject of threat management, does not automatically mean the student is a potential shooter or attacker; it simply means that a threat or concerning behavior (whether minor or serious) was reported and evaluated through the threat management process.

2. Threat management is not an emergency or crisis response. If there is an indication that violence is imminent, such as when a person is at school with a gun or other weapon, school staff must take immediate action by notifying law enforcement and following the school's emergency response plans.

3. Threat management is not a disciplinary process. School policy and procedures regarding discipline and referrals to law enforcement should be followed regardless of the threat assessment's outcome. Someone other than the threat management team will decide whether school discipline is appropriate. Information learned during the threat management process may be used in disciplinary or criminal proceedings, when appropriate.

4. The initial threat evaluation process may consider whether behavior constitutes a threat of self-harm because it is established that threats of self- harm may be a precursor to harm toward others. However, threat management is not to be used for suicide or self-harm assessment, services, or a mental health related safety plan. In cases where a threat to harm others may be accompanied by a threat to harm oneself, threat management should only address the harm toward others and the threat management team should coordinate with those providing self- harm intervention services.

n) Unfounded Determination: An unfounded determination means that there is not a sufficient factual basis to support the allegation, or it can be determined that the threats were never made; what was said was clearly not a threat; or the incident/behavior of concern did not happen or rise to the level of posing a threat or concern of harm to the school community. The reporting person may simply have been mistaken about the behavior or based upon known facts about the situation, behavior, and context, no risk of violence exists. This unfounded summary disposition should only be used when it is clear and articulable that there is no basis for concern. The case should be advanced to the next step for further evaluation if there is any doubt.

II. Effective January 1, 2024, each SBTMT and DTMT must use the Florida Model to assess the behavior of students who may pose a threat of harm to themselves or others and to coordinate intervention and services for such students. All reported threats or concerning behaviors and communications, even those determined to be unfounded, must be documented by the SBTMT along with any resultant action, using the Florida Model Instrument.

III. The Superintendent must designate a Threat Management Coordinator (DTMC) to oversee threat management at all public K-12 schools, including charter schools sponsored by or under contract with the district. The DTMC is the direct liaison between the school district and the Department of Education's statewide threat management coordinator. Pursuant to Rule 6A- 1.0019, F.A.C., the DTMC is responsible for ensuring the fidelity of the district's threat management program. The DTMC must:

a) Ensure that all district-level and school-level threat management team personnel are trained in threat management and on the Florida Model;

b) Serve as Chair of the District Threat Management Team and as the liaison to the Department of Education’s Office of Safe Schools (“Office”);

c) Assist School Based Threat Management Teams in the district.

IV. Each school district superintendent must designate a District Threat Management Team (DTMT) that will receive referrals from the School Based Threat Management Teams, assess serious situations, and provide support to school-based teams, including charter schools in their district. The DTMT may assist the SBTMTs (defined below) in providing on-going effective threat management, or after assessing the matter, the DTMT may refer the case back to the SBTMT for it to manage. The DTMT must include the District Threat Management Coordinator as Chair, persons from school district administration, and persons with expertise in counseling, instruction, and law enforcement.

V. Each school must have a School Based Threat Management Team (SBTMT) comprised of four (4) members, at a minimum, including persons with expertise in counseling, instruction, school administration, and law enforcement. The principal is responsible for appointing team members. The SBTMT must also include a member with personal knowledge of the student of concern who is the subject of threat management. Team members must meet the following requirements:

a. The counseling team member must be a school-based mental health services provider that is able to access student mental health records. This person must be a certified school psychologist, a certified school social worker, a certified school counselor, or a mental health professional contracted by the District to provide mental health services in schools.

b. The instructional team member must meet the definition of instructional personnel under Section 1012.01(2)(a)-(d), F.S., or must hold a current Florida Educator Certificate under Section 1012.56, F.S.

c. The school administrator team member must meet the definition of administrative personnel found in Section 1012.01(3), F.S. This should not be the school principal, or equivalent, unless they are the only administrator at the school, because the principal has administrative oversight of the SBTMT.

d. The law enforcement team member must be a sworn law enforcement officer, as defined by Section 943.10(1), F.S., including a School Resource Office, school-safety officer, or other active law enforcement officer. At a minimum, a law enforcement officer serving on a threat management team must have access to local Records Management System information, the Criminal Justice Information System, and the Florida Crime Information Center and National Crime Information Center databases. Officers serving on school- based threat management teams must also have clearance to review Criminal Justice Information and Criminal History Record Information. A school guardian, as defined under Section 1006.12(3), F.S., or a school security guard, as defined under Section 1006.12(4), F.S., may not serve as the law enforcement member of a threat management team. However, because of their role and need for situational awareness, school guardians and security guards may observe the SBTMT meetings and process and consult with the team. Because all SBTMT members must be trained in the threat management process, calling a patrol officer who has not been trained in threat management to serve ad hoc as the law enforcement member of an SBTMT meeting is not permitted. Charter schools will likely have to meet with the sheriff or police chief to have a law enforcement officer designated for their school who will serve on the SBTMT.

e. If none of the team members are familiar with the student of concern, the SBTMT Chair must assign a member of the school’s staff who is familiar with the student to consult with and provide background information to the threat management team. The person must be instructional or administrative personnel, as defined in Section 1012.01(2) and (3), F.S. Consulting personnel do not have to complete Florida Model training and may not participate in the decision-making process.

f. The principal of each school must appoint a Chair and Vice Chair of the SBTMT. The SBTMT Chair is the point person at each school for threat management and receives initial reports of all threats and concerning behavior that may result in harm toward self or others (although imminent threats must always be first reported directly to law enforcement). The Chair is responsible for triaging reported threats or concerning behavior and communications to determine whether the matter should be summarily closed or whether it should be reviewed by the full SBTMT.

VI. The duties of each threat management team include the coordination of resources and assessment and intervention with individuals whose behavior may pose a threat to the safety of school staff or students consistent with model policies developed by the Office of Safe Schools.

VII. Each threat management team shall identify members of the school community to whom threatening behavior should be reported and provide guidance to students, faculty, and staff regarding recognition of threatening or aberrant behavior that may represent a threat to the community, school, or self.

a. All threats or reports of concerning behavior should be taken seriously and thoroughly reviewed to determine their merit and the level of concern.

b. Threats made anonymously and through electronic communication must be assessed no differently than those made in-person or where the reporting party is identified.

VIII. Reporting Responsibility for Members of the School Community

a. Where an imminent threat to life or physical safety exists, school personnel must immediately report the matter to law enforcement.

b. Each school district must provide multiple avenues for information affecting school safety to be easily conveyed and received. The FortifyFL anonymous reporting app and various other options are provided so that potential threats can be easily reported. School personnel are responsible for knowing the reporting options in their districts.

c. If you see something, say something. Effective threat management relies on all school employees, volunteers, and service providers reporting any threat or concerning behavior. All students, parents, guardians and caregivers are also strongly encouraged to report any threat or concerning behavior.

d. Reports of concerns that may represent a threat to the community, school, or self must be routed to the Chair of each school's SBTMT immediately for intake, initial evaluation, and an initial merit determination. The Chair must be well identified to everyone on each school campus.

e. The school-based threat management process involves:

1. Identification of threatening or concerning behavior and reporting to the SBTMT Chair: Concerning communications or behavior may be personally received or observed by school personnel, or personnel may receive reports from others. Regardless of the source, school personnel must immediately report any behavior or

   communications that may constitute a threat or concern regarding school safety to the SBTMT Chair.

   Before or after school hours, school personnel should immediately report the situation to law enforcement for evaluation if appropriate, and report it to the Chair as soon as possible but no later than immediately upon returning to school on the next school day.

   There should be no unnecessary delay reporting a threat or other concerning behavior.

   If a school administrator receives the information before the SBTMT Chair, the time for the Chair of the SBTMT to review the report and complete the Intake and Case Disposition form begins at that time.

   The Chair must use the Intake and Case Disposition form to document the receipt of the threat or other concerning behavior.

2. Determining if the reported claim has a factual basis: The chair will initially evaluate the report to determine whether there appears to be a factual basis for the assertions that warrant further review. This determination must be completed in time for the SBTMT to meet the following school day if necessary. Unless the student or parent refuses, the Chair should interview the student of concern in all cases when making this determination. If the student or their parents or guardian refuse to allow the student to be interviewed, then the refusal must be documented. This initial interview to make a factual basis preliminary determination does not require use of the Student Interview form.

3. If the Chair determines that there is not a sufficient factual basis to support the allegation, the Chair may summarily close the matter as unfounded.

   This “unfounded” disposition is appropriate only when it is clear there is no factual basis; the case should be advanced to the next step if there is any doubt. When using this summary disposition, the Chair must complete the Intake and Case Disposition form and enter it in the threat management information system as soon as possible, but within one school day of receiving the report of concerning behavior. The principal must review the decision to close the case as soon as possible but within two school days and the district threat management coordinator must review the case as soon as possible but within two school days after its review by the principal.

4. Evaluating the reported claim for threat of harm to self, others, or both: If the Chair determines there is a factual basis for the reported threat or concerning behavior or decides that there is not enough information to summarily close the case as unfounded, the next step is to determine whether the concern is one of self-harm, harm toward others, or both. If the threat or concerning behavior contains a threat of self-harm, it must be immediately referred to the appropriate entity to conduct a self- harm assessment. There must never be any delay in reporting a threat of self-harm to the appropriate entity that can assess the threat and provide protective services in accordance with Policy 3.14.

   If the threat is self-harm only, with no other indicators of concern regarding potential harm toward others, then no further action is required by the Chair other than to appropriately document the referral on the Intake and Case Disposition form and summarily close the matter.

   For any of these summary dispositions, the closure by SBTMT Chair and the review by the school principal and district threat management coordinator must be documented in the threat management information system. The principal should review the decision to close the case as soon as possible but within two school days and the district threat management coordinator should review the case as soon as possible but within two school days after its review by the principal.

5. Determining if the case should be referred to the full SBTMT: In making the determination whether to refer the matter to the SBTMT, the Chair should consider all relevant factors, including:

a. the nature of the threatening or concerning behavior

b. circumstances surrounding the behavior;

c. the person's age and ability to carry out a harmful act;

d. the person's known baseline behavior; and

e. the person's history, or lack thereof, regarding similar concerning communications or behaviors, special needs manifestations, or other behaviors as reflected in school records.

If the threat of self-harm includes a potential risk of harm toward another person, or the matter is solely a risk of harm toward another person, and the Chair does not close as low-level, then the Chair must refer to the SBTMT.

If the Chair determines that the matter does not warrant review by the SBTMT and it should be summarily closed, then the Chair must assign the case a low level of concern. The Chair may refer the student for services, as appropriate, that are not part of an SSMP. The Chair should document the case on the Intake and Case Disposition form, including the reasons for not referring it to the SBTMT and if there was a referral to services, identify which services. The Chair should then close the matter and the decision to close the matter will be reviewed by the school principal and district threat management coordinator. The principal should review the decision to close the case as soon as possible but within two school days and the district threat management coordinator should review the case as soon as possible but within two school days after its review by the principal. The Chair should also refer the matter for review under the student code of conduct or other disciplinary process as appropriate regardless of whether the matter is referred to the threat management team. Whether the matter is referred to the threat management team has no impact on whether it is a School Environmental Safety Incident Reporting (SESIR) reportable event.

6. Initial assessment to assign a preliminary level of concern and determine if interim SSMP is necessary: If the Chair refers the matter to the SBTMT, the team must convene no later than the next school day after the concerning behavior was

   reported to the Chair or administrator, whichever was earlier. The Chair must determine whether an SBTMT member has personal knowledge of the student of concern and if not, identify a member of instructional or administrative personnel with personal knowledge of the student to consult with the SBTMT.At this initial meeting, the SBTMT must conduct an initial assessment, assign a preliminary level of concern (Low, Medium, or High), and determine the necessity to implement an interim SSMP.In assigning a level of concern, it is important to recognize that concerning behavior does not necessarily imply or predict that an individual or group will become violent. Instead, it serves as an indicator that the student may need intervention or increased supports to prevent the situation from progressing into a more serious situation. Proactive intervention and de-escalation are key and should be part of any approach to violence prevention. The Florida Model assigns a Low, Medium, or High level of concern to each concerning behavior or threat reported to the threat management team that cannot be summarily closed as unfounded.In assigning a level of concern, the SBTMT shall follow the DOE-approved factors and criteria.If the preliminary level of concern is low the SBTMT may implement an interim SSMP. If the preliminary determination is Medium or High, then it must implement an interim SSMP. (Note: If a change in placement is part of the SSMP and the student has an Individualized Educational Plan (IEP), a determination must be made whether the IEP was being implemented correctly at the time of the behavior, and whether the behavior was a manifestation of the student's disability. A manifestation means that the behavior had a direct and substantial relation to the disability. The SBTMT must consult with the appropriate authority within the district to make this determination if the student has an IEP. It is not the SBTMT 's role to make an IEP manifestation determination).After the initial meeting and required preliminary determinations, the SBTMT will then begin the assessment phase of the threat management process by using the threat management instrument. If the school does not have an automated system, then paper forms will be completed and forwarded through the district's established process.

7. Information gathering through interviews and data collection: The SBTMT will obtain background information from school records, law enforcement records, and mental health providers, as available, to evaluate more thoroughly the threatening or concerning behavior and determine whether a threat toward others or actionable concerning behavior actually exists. This detailed information collection should include questionnaires and interviews with:

a.the student of concern;

b. people familiar with the student, including parents and guardians;

c. witnesses to and the target of the threat; and

d. all the student's teachers.

There should also be a review of formal academic, disciplinary, and law enforcement records, and social media postings.

Upon a preliminary determination by the threat management team that a student poses a threat of violence to himself or herself or others or exhibits significantly disruptive behavior or need for assistance, authorized members of the threat assessment team may obtain criminal history record information, as provided in Florida Statutes. A member of a threat management team may not disclose any criminal history record information obtained pursuant to this section or otherwise use any record of an individual beyond the purpose for which such disclosure was made to the threat management team. The SBTMT shall obtain a comprehensive background report regarding the student of concern from law enforcement.

Information regarding threat factors, concerning behaviors, and protective factors should be analyzed in the context of the student of concern's age and development to determine the credibility and seriousness of the threat.

As deemed appropriate for cases with a preliminary High or Medium level of concern, a school-based mental health services provider may complete mental health interview forms of the student of concern, as well as the parent or guardian. The purpose of the mental health interview is to help the SBTMT determine appropriate services that may benefit the student as part of the SSMP when applicable. The mental health service provider shall conduct necessary screening and determine the need for further referrals for mental health services consistent with Policy 3.14 and/or evaluate in conjunction with the school based threat management team/SRO if involuntary examination is necessary and appropriate. A list of community based mental health and service providers is available on the Student Services page of our website (sarasotacountyschools.net) under the “Family Resources” section. If the mental health professional conducting these interviews is not a member of the SBTMT, it may be helpful for an SBTMT member or other school administrator to be present.

8. Assigning a concern level: There are four possible dispositions:

a. Close as unfounded;

b. Low Level of Concern (With or Without SSMP)

c. Medium Level of Concern;

d. High Level of Concern

The determination of what level of concern to assign shall be made based on an evaluation of DOE-approved factors and criteria.

If not unfounded or low level of concern, evaluating for Medium or High level of concern;

9. Referral to DTMT for some Medium cases and all High levels of concern:

a. If the SBTMT determines that the level of concern is Medium, the DTMC upon review may refer the case to the DTMT for its consideration.

b. If the SBTMT determines that the level of concern is High, then the DTMC must refer to the DTMT for review.

The DTMT must convene to consider the case within two school days of receiving the referral from the DTMC.

The DTMT may refer the case back to the SBTMT without providing additional support or oversight or may provide additional and ongoing support to the SBTMT.

10. Creating SSMP, when appropriate: The Student Support Management Plan is not punitive or part of a disciplinary process. The SSMP is a student support and management plan that uses direct and indirect interventions to help create an environment less likely to produce violence. The SSMP identifies mandatory action steps that are needed to ensure school safety and responses that can help support the student of concern and make positive outcomes more likely. The action steps selected will comprise the SSMP. The resources and other support the student needs will differ depending on the information gathered during the assessment, including the mental health interviews when applicable and identified protective measures.

a. Creating the Student Support and Management Plan (SSMP):

1. The SBTMT should develop the SSMP with input from the student's parent or guardian, including but not limited to information learned during the mental health interviews, if they are conducted.

2. Some actions may need to be taken immediately, while others (e.g., IEP meetings) may need to occur at a later time.

3. The SBTMT will identify in the SSMP any long-term action that requires gradual implementation and continual monitoring.

4. Any disciplinary referrals should be noted in the SSMP for future situational awareness only because the SSMP is not disciplinary in nature.

5. The SBTMT will also identify any protective actions to be taken with potential victims of the threat or any students impacted by the threat or concerning behavior.

6. The SSMP must include a timeline for plan monitoring and completion. The SSMP should contain accountability measures to ensure it is an effective plan.

b. Some of the possible resources and supports that may comprise the SSMP include, but are not limited to:

1. Holding parent/guardian conferences to discuss the SSMP;

2. Implementing anti-bullying best practices that provide consequences for the aggressor, as well as support for the victim;

3. Consideration of potential schedule changes;

4. Assigning a mentor;

5. Providing mental health and resiliency support;

6. Consideration regarding extracurricular activities;

7. Requiring regular meetings with a counselor at school;

8. Referring the student to outside mental or behavioral health services;

9. Requiring daily searches;

10. Requiring social media monitoring;

11. Requiring a teacher or staff to escort the student throughout the school campus;

12. Recommending to the appropriate authority removal or expulsion from schools;

13. Restricting the use of computers or other electronic devices.

c. The SSMP requirements will be documented on the Intake and Case Disposition form. The SSMP must be consistent with the following minimum timeframes for SSMP implementation and monitoring:

1. Low level of concern: 90 days minimum

2. Medium level of concern: 180 days minimum

3. High level of concern: One year minimum.

d. The requirements of an SSMP are established by the SBTMT and must be adaptable to meet the needs of the situation.

e. The specific frequency of contact with the student during the SSMP period will vary based on the need to adequately monitor the student and ensure others' safety. SSMPs should be coordinated with law enforcement regarding off-campus threat management when appropriate. The SBTMT is required to meet monthly, assess each SSMP for its effectiveness, and make modifications as appropriate. Modifications to the SSMP will be documented on the SBTMT Monitoring Form for Monthly Meeting form. The monthly assessment, or more frequently as determined by the SBTMT, must occur for the duration of the monitoring period.

f. School-based and district threat management team members must follow

established policies and procedures, consistent with Sections 1006.07(7) and 1012.584, F.S., for referrals to school-based, community, or healthcare providers for mental health services, evaluation, or treatment as part of the SSMP. If an immediate mental health or substance abuse crisis is suspected, school personnel must follow existing policies to engage resources, including, but not limited to, law enforcement officers who have been trained in crisis intervention.

11. Continual monitoring of the student during the SSMP period and continual evaluation of the SSMP to ensure it is effective: The SBTMT is required to meet monthly, assess each SSMP for its effectiveness, and make modifications as appropriate.

    At least 30 days before the end of the initial SSMP monitoring period for the assigned level of concern, the SBTMT must consider the matter again and assess whether to close the case upon expiration of the monitoring period or extend the SSMP. If the decision is to extend the SSMP, requirements may be added or deleted and documented on the SBTMT Monitoring Form for Monthly Meeting.

    Any SSMP reassessment may not result in the initial level of concern category being changed to a lower level based on subsequent circumstances; however, the SSMP's requirements may be modified downward as the matter is periodically reviewed. The matter may also be reconsidered at any time based on new or additional information and the level of concern may be increased. If the level of concern is increased, then the SSMP must be modified and documented as appropriate with the new level.

    If a student is facing possible assignment to an alternative school, suspension, or expulsion as a consequence of their actions, the school should consider ways in which these can be safely enacted and identify resources that may assist the student during this time. These necessary events may actually exacerbate the pathway to violence and trigger violence, and the school should – consistent with FERPA and other laws - actively consult with law enforcement because the school-based threat may become a community-based threat.

IX. Each SBTMT must meet as often as needed to fulfill its duties of assessing and intervening with persons whose behavior may pose a threat to school staff or students, but no less than monthly. Each threat management team must maintain documentation of their meetings, including meeting dates and times, team members in attendance, cases discussed, and actions taken.

X. The importance of parental notice cannot be overstated in the threat management process. Explaining the purpose of threat management and the concerning behavior to a parent or guardian provides them with the opportunity to support the student and provides an opportunity for the school community to enlist the support of a parent in threat management process itself. Because parental involvement in threat management can improve outcomes, the SBTMT should consider involving parents and guardians throughout the process.

The minimum notification requirements are:

a. Where a report of concern includes an identified student target, the SBTMT Chair must make a reasonable effort to notify the parent of the targeted student before the end of the school day that the report was received, unless the Chair has determined the concern is unfounded. The unfounded summary disposition should only be used when it is clear and articulable that there is no basis for concern. If there is any doubt, the case should be forwarded to the full School Based Threat Management Team for further evaluation and parent notification should occur. Nothing herein prevents the school from notifying parents or guardians if they believe it is in the best interest of the student.Consistent with 34 C.F.R. 99.36, personally identifiable information may be disclosed to appropriate parties, including parents of student targets in connection with an emergency if knowledge of that information is necessary to protect the health or safety of the students or individuals.In making a determination to so disclose such information, the SBTMT Chair may take into account the totality of the circumstances pertaining to the threat to the health or safety of a student or other individuals. If the Chair determines that there is an articulable and significant threat to the health or safety of a student or other individuals, the Chair may disclose such information to any person whose knowledge of the information is necessary to protect the health and safety of the student or other individual so long as there is a rational basis for the determination.When such an emergency requiring such disclosure exists, nothing prevents the disclosure of appropriate information:

1. to District teachers and school officials at the school who have been determined to have legitimate educational interests in the behavior of the student; or

2. to teachers and school officials in other schools school who have been determined to have legitimate educational interests in the behavior of the student.

b. If the Chair of the SBTMT determines that the reported behavior is low level of concern and summarily closes the report, the Chair or his/her designee must use reasonable efforts to notify the parent or guardian of the student of concern prior to the end of the school day on the same day as the report is closed.

c. If the Chair does not summarily close the case and refers it to the SBTMT, reasonable efforts must be made to notify the student of concern's parent prior to the end of the school day on the same day the SBTMT assigns the preliminary level of concern.

d. If the level of concern is High (preliminary or final disposition), the Chair or his designee must notify the superintendent or his designee to ensure that the notice requirements of Section 1006.07(7)(e), F.S., are met. This section provides as follows:

1. Upon a preliminary determination that a student poses a threat of violence or physical harm to himself or herself or others, a threat management team shall immediately report its determination to the superintendent or his or her designee. The superintendent or his or her designee shall immediately attempt to notify the student's parent or legal guardian. Nothing in this subsection precludes school district personnel from acting immediately to address an imminent threat.

e. Parents or guardians must also be notified if the threat management process reveals information about their student's mental, emotional, or physical health or well-being, or results in a change in related services or monitoring, including but not limited to implementation of an SSMP.

f. Reasonable efforts must be made to notify the student of concern's parents or guardians on the same day the SBTMT concludes final disposition.

g. Once an SSMP is finalized and anytime it is substantively revised, the SBTMT Chair or designee must provide a copy of the SSMP to the student of concern's parent or guardian. The targeted student's parent or guardian should also be informed that an SSMP has been implemented.

The SBTMT Chair or designee must document all attempts to make contact with the parent or guardian.

Nothing herein precludes school district from acting immediately to address an imminent threat.

The timelines for notice may be modified where the team reasonably believes and documents that disclosure by the time designated above would result in abuse, abandonment, or neglect, as defined in Section 39.01, F.S.

IX. When threat management is necessary it must be conducted for all students regardless of whether they have a disability. Threat management must always be based on an individualized assessment that is based on current information and should not be based on generalizations or stereotypes about the effects of a particular disability. Threat management teams should direct their attention to symptoms and behaviors, rather than formal diagnoses, to assess a concern for violence. In addition, behaviors exhibited by a student with a disability need to be evaluated in the context of that student's known baseline of behavior.

Issues involving students with disabilities and threat management are fact-specific and should be discussed with legal counsel. A summary of federal regulations implementing the I.D.E.A. includes:

a. Removal for less than 10 days: School personnel may remove a student with a disability who violates a code of student conduct from his or her current placement to an appropriate interim alternative educational setting, another setting, or may suspend the student for not more than 10 consecutive school days (to the extent those consequences are also applied to students without disabilities). Students with disabilities may be subject to removals of not more than 10 consecutive school days in that same school year for separate incidents of misconduct. 34 C.F.R. s. 300.530(b)(1).

b. Change in placement: If a student with a disability is removed from his or her current placement for 10 school days in the same school year, it is considered a change in placement. 34 C.F.R. 300.536. During any subsequent days of removal, the local education agency (LEA) must provide services as required under 34 C.F.R. s. 300.530(d).

1. Services may be required when a student with a disability is removed from his or her current placement for less than 10 school days, if those services are also provided to a student without a disability that is similarly removed. 34 C.F.R. s. 300.530(d)(3).

c. Manifestation determination: Within 10 school days of a change in placement of a student with a disability based on a violation of the code of student conduct, the LEA, parent and other members of the IEP team must review all relevant information and must determine:

1. If the conduct in question was caused by, or had a direct and substantial relationship to the student's disability; or

2. If the conduct in question was the direct result of a failure to implement the student's IEP, and if so, take steps to remedy the issue. 34 C.F.R. s. 300.530(e).

d. If the behavior is determined to be a manifestation of the student's disability: The IEP team is required to conduct a functional behavioral assessment and implement a behavioral intervention plan, or if one is already in place, the plan must be reviewed and modified as needed to address the behavior. The parent and LEA may agree to a change in placement as part of the modification to the behavioral intervention plan. 34 C.F.R. 300.530(f).

e. If the behavior is determined not to be a manifestation of the student's disability: Disciplinary procedures may be applied in a same manner as they would to students without disabilities, except that students with disabilities must continue to receive educational services. 34 C.F.R. 300.530(c)-(d). The IEP team may also consider whether the student's IEP needs to be revised. A change in placement is also permitted with parental consent.

f. If the threat assessment team and school administration determine that it is not safe for a student to remain in his or her current placement, the IDEA allows for a temporary alternative placement of up to 45 school days, even where the behavior in question was determined to be a manifestation of the student's disability. A temporary alternative placement is available only if the student:

1. Carries a weapon to or possesses a weapon at school, on school premises or at a school function;

2. Knowingly possesses or uses illegal drugs, or sells or solicits the sale of a controlled substance, while at school, on school premises or at a school function; or

3. Inflicted serious bodily injury on another person while at school, on school premises or at a school function. 34 C.F.R. 300.530(g).

g. If an LEA believes that maintaining the current placement of a student with a disability is substantially likely to result in injury to the student or others, the LEA may request a hearing, where a hearing officer will determine whether the student should be returned to their previous placement (if removal was improper or that the behavior at issue was a manifestation of the student's disability) or can order a change in placement for up to 45 days. 34 C.F.R. s. 300.532(a)-(b).

1. These procedures may be repeated, if the LEA believes returning the student to the original placement is substantially likely to result in injury to self or others. 34 C.F.R. s. 300.532(b)(3).

XII. Threat assessments and records related to threat management are considered education records as defined by the Family Educational Rights and Privacy A

XIII. Notwithstanding any other provision of law, all state and local agencies and programs that provide services to students experiencing or at risk of an emotional disturbance or a mental illness, including the school districts, charter schools, school personnel, state and local law enforcement agencies, the Department of Juvenile Justice, the Department of Children and Families, the Department of Health, the Agency for Health Care Administration, the Agency for Persons with Disabilities, the Department of Education, the Statewide Guardian Ad Litem Office, and any service or support provider contracting with such agencies, may share with each other records or information that are confidential or exempt from disclosure under chapter 119 if the records or information are reasonably necessary to ensure access to appropriate services for the student or to ensure the safety of the student or others. All such state and local agencies and programs shall communicate, collaborate, and coordinate efforts to serve such students.

If an immediate mental health or substance abuse crisis is suspected, school personnel shall follow policies established by the threat management team to engage behavioral health crisis resources. Behavioral health crisis resources, including, but not limited to, mobile crisis teams and school resource officers trained in crisis intervention, shall provide emergency intervention and assessment, make recommendations, and refer the student for appropriate services. A student referred for mental Health referral must have parent/guardian signature indicating consent or declining services.

Onsite school personnel shall report all engagements with behavioral health crisis resources and other actions taken to the threat management team, which shall contact the other agencies involved with the student and any known service providers to share information and coordinate any necessary follow-up actions. Upon the student's transfer to a different school, the threat management team shall verify that any intervention services provided to the student remain in place until the threat management team of the receiving school independently determines the need for intervention services.

XIV. All members of SBTMTs and DTMTs must be trained on the Florida Model through training provided by or approved by the Office of Safe Schools, as follows:

a. All SBTMT and DTMT members must complete basic Florida Model training.

b. The District Threat Management Coordinator must complete additional training specific to the Coordinator role.

c. School principals, the Threat Management Chair, and the Vice Chair must complete additional training specific to their respective roles.

d. In order to switch to the Florida Model on January 1, 2024, District Threat Management Coordinators, SBTMT members, school principals, and DTMT members must complete Office-approved training no later than December 31, 2023.

Beginning with the 2024-25 school year, district and school-level teams must be designated before the start of the school year. Team members who have not previously completed training must complete Florida Model training before the start of the school year. Those appointed to threat management teams after the start of the school year must complete Florida Model training

within sixty (60) days of appointment.

Beginning with the 2024-25 school year, district and school-level team members who have been fully trained in a previous school year must complete an annual refresher training provided by the Office within the first sixty (60) days of school.