Proposed, for board reviewRegional template and one pilot district in months 2 to 6; remaining districts asked to sign by year end
Plug into the threat assessment system the region already runs
A written agreement with the High Desert Education Service District (the regional agency that supports all six school districts) and each district, drafted once through the ESD's counsel, that names the roster as a referral destination in the student's management plan (the list of supports the team assigns), not a seat on the regional threat assessment team (Level 2); spells out the two-way parent release and the separate youth authorization; returns four status words to the school and nothing to the law enforcement record; states that the network would never file or supply information for an extreme risk protection order (ERPO) petition; makes any re-entry offer unconditional; and asks the ESD to publish counts of referrals by county, disability status and race, with no names.
Threat assessment without fast follow-up care produces a list of worried-about children and nothing else. Central Oregon adopted the system Salem-Keizer built in 1999 because its earlier referrals to county behavioral health produced no follow-through. In Florida, where the data are best, about three quarters of assessed students received some service but only a third received mental health services. The regional program (the Level 2 team, which brings in county and law enforcement partners) is staffed by a small ESD team, and, as the roster strategy on this site shows, few providers reported openings outside Bend.
The handoff also fails on paperwork. Without a parent’s consent, a school may share education records under the emergency exception in the federal student records law (FERPA) only while there is an articulable and significant threat, never as a blanket release, so a routine referral needs a signed parent release. Central Oregon also keeps threat assessment files in a law enforcement unit record, outside the education record. Six districts’ counsel reviewing six different forms could mean a year of delay, so we propose that the ESD commission one regional template and that every district review the same document once. Counselor-initiated referrals on parent consent, which need no agreement with the regional team, would start while that happens.
A gun-owning parent will read a school flag, a police file and a therapist as three steps to a protective order petition, and the family of a student with a disability will read a care offer tied to re-entry as coerced treatment. The agreement would answer both in writing: four status words back, nothing into the law enforcement record, the network would never file or supply information for a petition, lawful hunting is not an indicator, referral runs parallel to and never in place of special education services, and re-entry is never conditioned on accepting help.
Why we think it works
- Central Oregon educators switched to the threat assessment system that Salem-Keizer created in 1999 because their previous program was inefficient: referrals to Deschutes County Behavioral Health produced no follow-through. The article gives no adoption year for Central Oregon and describes the system as implemented at the start of a recent school year. (Central Oregon schools employ successful threat assessment program, The Bulletin, moderate evidence)
- Of 23,134 Florida students assessed in 2021 to 2022, about three quarters received a service but only 33 percent received mental health services. (How do schools support students after a behavioral threat assessment? Maeng, Cowley, Co..., strong evidence)
- Students in schools using the Comprehensive School Threat Assessment Guidelines were about four times more likely to receive counseling and one third as likely to receive long-term suspension. (Overview and Research Summary of the Comprehensive School Threat Assessment Guidelines..., moderate evidence)
- Under the health or safety emergency exception in the federal student records law (FERPA), one of several exceptions to its consent requirement, a school that determines there is an articulable and significant threat may disclose education records to anyone whose knowledge is necessary to protect health or safety, limited to the period of the emergency. The federal health privacy law (HIPAA) permits a provider to alert school administrators when a patient makes a credible serious and imminent threat. (Joint Guidance on the Application of FERPA and HIPAA to Student Health Records, Decembe..., strong evidence)
- The Central Oregon protocol defines a Law Enforcement Unit Record, a manila envelope kept within the student's cumulative file, which may contain copies of threat assessments and other documentation not considered part of the education record. (Behavioral Threat Assessment Definitions, Central Oregon School Safety, strong evidence)
What we would do
- Ask the ESD's Director of Safety and Response and the Safe Schools Alliance (the ESD's regional school safety partnership) for a 30-minute slot to present the roster as supplementary capacity for young people the county and BestCare (the community behavioral health provider in Madras and Prineville) cannot see within ten business days, not a parallel process and not a new member of the regional team; the county remains the referrer of last resort.
- Ask the ESD to commission one regional template set through its counsel, with the group paying for the review: a release under the federal student records law (FERPA) for the school, an authorization under the federal health privacy law (HIPAA) for the clinician, and a separate authorization for ages 14 to 17; a counselor presents the release separately from the regional team meeting, in the family's language, with time to consider.
- Start with counselor-initiated referrals on parent consent while the template is reviewed; pilot the full agreement with one district before asking six.
- Define a one-page referral packet (the concern, the management plan items assigned to care, consent on file, who to call back) drawn from nothing in the law enforcement unit record and carried by the family; a four-step feedback line (acknowledged, first contact made, in care, closed) and nothing more; nothing from the clinician enters the law enforcement record; a gun-owner parent on the board reviews the release form before it is used.
- Write in: the Care Network would never file or supply information for a protective order petition; only a school-generated referral moves, never tip content; referral is voluntary and runs parallel to, never in place of, special education and disability accommodation plans (IEP or 504); any suspension, expulsion or transfer of an assessed student triggers an unconditional care offer plus a named adult at school, and re-entry decisions are never conditioned on accepting it.
- Run one joint two-hour training per county for the school and regional threat assessment teams, school counselors and roster clinicians on the student records law, the health privacy law, Oregon's law on when a minor can consent to care, the local protocol and the emergency exception; the training states that lawful hunting and shooting sports are not indicators and that reason for referral is recorded alongside demographics.
- Ask, never condition: request that the ESD publish its own annual counts of referrals by county, disability status and race, with no names and with numbers too small to protect privacy left out, and offer to fund the analysis through the evaluation partner; a disability rights reviewer reads the agreement before signature.
- Add a capacity clause: referrals accepted up to the posted weekly capacity by town; beyond that the ESD routes to the county and BestCare as it does today; no referral before the fiscal sponsor's certificate of insurance naming the district is on file.
How we would know it is working
- Regional template drafted and the pilot district asked to sign by month six; remaining districts reported as signed or pending at year end
- Percent of referrals arriving with consent on file, and percent with feedback returned to the school within ten business days
- Median days from school flag to first clinical contact, target under ten business days
- Re-entry offers made after removals (counts only)
- Request for annual published referral counts made to the ESD, with funding offered; status reported
What could get in the way
- Level 2 assessments sit in a law enforcement unit record and the regional team includes district attorney and juvenile justice offices; a roster as the standing path out of that file looks like three steps to a petition, and no gun-owning parent signs.
- Four status words back and nothing into the record, written into the agreement and the release; the network would never file or supply information for a petition; the health privacy law permits but does not require a clinician to alert a school, and only for a credible serious and imminent threat; a gun-owner parent reviews the form.
- Rural kids get flagged for talking about hunting or posting a photo with a deer rifle.
- Training for the school and regional teams would state that lawful hunting and shooting sports are not indicators, that assessment looks at behaviors and communications, and that reason for referral is reported with the demographics.
- Six district counsels and a small ESD team make months 2 to 6 optimistic, and a nonprofit cannot be added to a team created by state law without the ESD, county, district attorney and juvenile justice offices agreeing.
- One regional template through the ESD's counsel, counselor referrals on parent consent first, one pilot district, and the roster named as a referral destination rather than a team member; count on year end.
- Demographic reporting as a condition of partnership inverts the relationship, a re-entry clause ties treatment to discipline, and breakdowns in small districts re-identify students.
- Ask and fund rather than condition; the offer is unconditional and made once through the family; the ESD would be asked to publish its own counts with small numbers left out, and the group holds none of it.
Who we would work with: The ESD's Student Threat Assessment System and Safe Schools Alliance, Bend-La Pine, Redmond, Sisters, Crook County, Jefferson County 509J and Culver school districts and their counsel, Deschutes County Behavioral Health and BestCare (existing members of the regional team), County juvenile justice and district attorney offices, A disability rights reviewer, Fiscal sponsor (the established nonprofit that would hold the group's contracts and insurance)