Removing Suicidal Students From Campus: The
Significance Of Recent Changes In Federal Policy
Dr. MJ Raleigh
Director of Counseling and
Psychological Services
University of North Carolina at
Pembroke
mj.raleigh@uncp.edu
Presenter
MJ completed a PhD in environmental studies at
Antioch University, focusing on the interaction
between environment and mental health. She is
currently the CAS director representing ACCA at the
national council and is a past ACCA president (20112012).
MJ has over 25 years of experience working with
college students on campus with 20 of those years as
a director of mental health services.
She is currently the Director of Counseling and
Psychological Services at the University of North
Carolina at Pembroke. mj.raleigh@uncp.edu
OCR Title II Shift
Who Are We Talking About?
Campus Impact & Opportunity
Policy Implications
Beyond Separation: Treatment
Resources for Prevention
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OCR Title II Shift
In 2010, Title II of the Americans with Disabilities Act
was revised (effective March 15, 2011):
• Applies to public colleges & universities
• Likely also extends to private colleges & universities
through OCR’s similar interpretation of Section 504
• Added direct threat language into Title II
• Aligns Title II and Title III by clarifying that use of the
direct threat standard applies to cases involving harm
of others, not harm to self
www.ada.gov/regs2010/titleII_2010/titleII_2010_withbold.htm
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OCR Title II Shift
So what?
This demonstrates a shift from some prior
interpretations of Title II, where guidance was given to
apply the direct threat standard to self-harm.
“Direct threat means a significant risk to the health or
safety of others that cannot be eliminated by a
modification of policies, practices or procedures, or by
the provision of auxiliary aids or services.”
www.ada.gov/regs2010/titleII_2010/titleII_2010_withbold.htm
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OCR Title II Shift
To determine if a direct threat exists, a college must make:
• An individualized assessment
• Based on reasonable judgment
• That relies on current medical knowledge OR on the best
available objective evidence, to ascertain:
• The nature, duration, and severity of the risk
• The probability that the injury will actually occur
• Whether reasonable modifications of policies,
practices, or procedures or the provision of auxiliary
aids or services will mitigate the risk.
www.ada.gov/regs2010/titleII_2010/titleII_2010_withbold.htm
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OCR Title II Shift
What does this mean?
As a result of the change in language in Title II of the
Americans with Disabilities Act (ADA), the revised
regulation now deems it unlawful to take adverse action
(i.e. involuntarily separate, suspend or expel) towards a
student solely on the basis of self-harmful or suicidal
behaviors.
This is why most of you are here with us today.
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OCR Title II Shift
Additional Resources:
• The National Center for
Higher Education Risk
Management (NCHERM)
and the National
Association of
Behavioral Intervention
Teams (NaBITA) offer a
white paper to address
this issue.
www.nabita.org/documents/2012NCHERMWHITEPAPERTHEDIRECTTHREATSTANDARDFINAL_000.pdf
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OCR Title II Shift
The National Association of College and University
Attorneys released a document with a focus on New
Title II Regulations Regarding Direct Threat: Do They
Change How Colleges and Universities Should Treat
Students Who Are Threats to Themselves?
http://counsel.cua.edu/nacuanotes/titleIIregulations.cfm
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OCR Title II Shift
The National Association of College and University
Attorneys (NACUA) created a webpage with case
examples, articles and information addressing
distressed and suicidal students.
www.nacua.org/lrs/NACUA_Resources_Page/SuicidalStudentsResources.asp
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Who Are We Talking About?
Who is a chronically suicidal student?
– Daria has a history of suicide attempts in high
school. During her first semester at college, she
overdosed on pills resulting in a hospitalization. She
often tells other students “I’m always depressed and
think of killing myself.” Her friends are beginning to
complain to faculty/staff that they feel like they have
to keep an eye on her, especially after she has been
drinking. Last week, medical and counseling staff
responded to her when she was in crisis and she
refused to be transported by the paramedics when
they suggested she go to the hospital.
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Who Are We Talking About?
How do we identify suicidal students?
– Actual Attempts (taking pills)
– Direct Verbal Clues (I’ve decided to kill myself)
– Indirect Verbal Clues (I just want out)
– Behavioral Clues (giving away items, acquiring
weapon, previous suicide attempt)
– Situational Clues (loss of relationship, suspension)
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Who Are We Talking About?
Who is a delusional/paranoid student?
– David has OCD and is prone to panic attacks during
high anxiety times. One day, he sought out his
counselor and informed her that he usually carries a
knife with him for protection, but he was concerned
because today on the bus he felt like his mind was
telling him to stab someone else. He agreed to be
evaluated and was hospitalized for a 3-day inpatient
stay.
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Who Are We Talking About?
How do we identify delusional/paranoid students?
Delusions are strongly held beliefs despite evidence to the
contrary (schizophrenia, manic bi-polar)
Bizarre delusion: strange and completely implausible
“My blood is green and I can see other people’s
thoughts.”
Non-bizarre delusion: false, but plausible
“I’m under constant FBI and police surveillance.”
Common Themes: control, nihilistic, grandiose religious
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delusion, persecutory
Campus Impact & Opportunity
A single event can have rippling effects throughout the
community
– Faculty in the Classroom
– Residence Hall/Floor
– Athletic Teams
– Clubs and Organizations
– Family and Parents
– Admissions and University PR
– Students already struggling “on the edge”
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Campus Impact & Opportunity
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Campus Impact & Opportunity
Consider the impact:
•Is it actual or speculative?
•Is it threatening or disruptive?
•Is it annoying, uncomfortable, or unknown?
Consider the opportunity:
•Does this provide a way to learn more about the
individual’s behavior and motivations?
•Does this open the door to develop or utilize caring
relationships or support?
•Are there interventions the College can take that might
not otherwise occur for the individual?
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Campus Impact & Opportunity
Everyone’s goal is for the student to be successful.
Instead of jumping immediately to separation as the
solution, look for ways to support him or her.
• Conduct appropriate assessment, which usually involves
a person talking to the student.
• Determine if “reasonable modifications of policies,
practices or procedures” can be made.
• Determine if “auxiliary aids or services” can mitigate
the risk.
Relationships, conversations, and an ethic of care
promote student success more than separation does.
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Campus Impact & Opportunity
Institutionally train and support people at all levels:
– Value of interdisciplinary teams and approaches
– Empower the person that the student trusts
– Educate faculty and front line staff
– Talk to parents . . . AND to students
– Invite the people you need to the table
– Create a culture of reporting
– Do not let FERPA get in the way of helping a student
– Develop policies and procedures that balance the
student’s rights with the institution’s concerns
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Policy Implications
•
•
•
•
General Suggestions
Involve the student in the conversation.
Discuss common goals for the student and the
school (e.g., graduation, good grades, financial aid
eligibility)
Involve family in a cooperative process; build
alliances
Have conversations ahead of time about behavioral
agreements, leave vs. withdrawal, what it means to
be a qualified student, etc.
Policy Implications
General Policies & Procedures
•Ensure that policies are published and followed –
including if your BIT has authority to act.
•Adverse action based solely on self-harm, or policies that
describe conditions that are protected are not permitted.
•Have campus dialogue about what constitutes disruption
and threats, and what to do about them.
•Offer basic procedural protections (notice, hearing,
appeal).
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Policy Implications
Conduct Procedures & Codes
• Offer appropriate due process and follow your process.
• Use clearly written codes and referrals based on
behaviors, not disabilities or conditions.
• Address actual significant disruption to campus, not
simply risk of disruption.
• Be consistent in referrals – the same disruptive behavior
should warrant a conduct process, regardless of the
individual. Sanctioning should also be consistent.
• Do not treat students with disabilities differently than
other students, other than providing reasonable
accommodations under the law.
Policy Implications
Behavioral Intervention/Risk Assessment
• Educate the campus to identify behaviors (not
conditions) that warrant a referral.
• Have a risk assessment and intervention model that
you apply consistently, including when to refer to
conduct.
• Consider BIT as a proactive intervention when there is
a risk of disruption or harm. Conduct can serve as the
process for an actual disruption.
• Distinguish between BIT and the conduct process.
Policy Implications
Voluntary Medical Leave
•
•
•
•
•
•
•
Be flexible and generous with voluntary leave
Advocate for student with regard to grades
Offer tuition refund/vouchers
Talk about future plans and return
Cover evaluations costs
Involve family or support systems
Assist with referrals – get everyone at the table once
Policy Implications
Involuntary Separation
• Interim suspension or involuntary leave may still be
invoked if there is a determination that a student poses
a direct threat of harm to others.
• Ensure that the policy is well-written, and is applied
narrowly and appropriately.
• Action should be invoked based on a student’s
behaviors (actions, statements, etc.), and not
speculation or a student’s disability.
Policy Implications
Returning After Leave/Separation
• Students who are suspended through a conduct
process may have to complete sanctions to return.
• If there are guidelines for return after leave, they
should apply regardless of a disability, not because
of it.
• Can’t require “treatment” but you can require
documentation of resolution of the behaviors of
concern, so long as you require that of ALL students
who qualify for and receive a comparable leave.
Policy Implications
•
•
•
•
Consider:
The types of disruption on a residential vs. a
commuter campus
What constitutes “reasonable”
Potential for increased risk (triggers) due to
separating students
“Discomfort” ≠ Disruption
Beyond Separation: Treatment
It’s a simple word, ‘treatment’, but what do we mean?
– Case management
– Understanding level of care
– Expanding scope of practice; understanding referral
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Beyond Separation: Treatment
Invest in Case Management
• Counseling Center Models
• Administrative Models
– Student Affairs
– Behavioral Intervention Team
– Student Conduct
– Emergency Management
– Provost’s Office/Academic Affairs
– Human Resources
• Third party company as a pay service
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Beyond Separation: Treatment

Student Affairs: Case management runs out of the student
affairs/dean’s office or through campus BIT. Focus on meeting
with students, follow-up, ensuring connection to various
departments and that a student doesn’t “fall through the
cracks.” Open in terms of communication (FERPA).

Counseling: Case management focuses on at-risk counseling
students and students who need direct connection to counseling.
Communication may be more difficult given the limits of the
client relationship (State Confidentiality law).

Off-Site: Case management is run through a third-party
company and offers similar service as a student affairs or
counseling approach. May be a pay-for-fee service.
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Beyond Separation: Treatment
Counseling Model
• Primary focus on the
individual
• Connection to treatment
options
• Communication between
medical providers
• Self-care through
assessment of obstacles and
obtaining solutions
Administrative Model
• Primary focus on balancing
individual and community
• Connection to on or offcampus resources
• Communication within
institution
• Code of Conduct offers
accountability for behavior
that causes disruption
Beyond Separation: Treatment
Understanding Level of Care
– Online support/para-professional (RA)/friend
– Consulting evaluation (stop by)
– Outpatient treatment:
– Weekly or bi-weekly
– Psychological Testing
– Medication Referrals
– Case Management/Team meeting
– Partial Day treatment (1x/week)
– Crisis Stabilization Unit
– Inpatient Unit
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Beyond Separation: Treatment
Scope of Practice/Referral
http://chronicle.com/article/Giving-Troubled-Students-the/130838/
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Beyond Separation: Treatment
Scope of Practice/Referral
– Expanding training for counselors, psychologists and
social workers
– Removing session limits, following 75/25 rule
– Avoid blacklisting certain disorders
– Make sure a referral ‘sticks’
– Social Advocacy
– Health services (WKU example)
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Resources for Prevention
Educate the campus & demystify:
 Orientation programming
 Creative speakers to talk about mental illness
 Awareness campaigns
 Train those who see students:
•
•
•
•
•
Faculty and administrators
Office staff
Coaches and advisors
Police, parking, and custodial
Student leaders and RA’s
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Resources for Prevention
Resources:
• The JED Foundation
• Active Minds: www.activeminds.org
• www.facebook.com/BipolarBoy
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Resources for Prevention
QPR
• QPR is one approach to educating staff, faculty, and students in
order to prevent suicides on campus.
• This approach is similar to CPR in its focus on training those in a
short, 90-minute session provided to non-clinical staff
– Question signs/symptoms of suicidal behavior
– Persuade people to get help
– Refer them directly to that help
• QPR training is $495 for 1 day training that allows the trainer to
offer it on campus.
http://www.qprinstitute.com/
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Resources for Prevention
safeTALK:
• safeTALK: is suicide alertness for everyone and teaches
participants how to recognize when thoughts of suicide are
present & initiate alert steps to get some assistance.
• The TALK steps are Tell, Ask, Listen, and Keep Safe. The
training includes discussion of why persons might miss,
dismiss, or avoid the idea of suicide and offers participants
the opportunity to practice TALK steps.
• safeTALK participant cost is $6 (resource book, pocket card,
sticker, and certificate). safeTALK training for trainers cost is
$400-600 (cost is lower if you have 10 trainer candidates).
Trainer prerequisite is ASIST training.
www.livingworks.net
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Resources for Prevention
ASIST:
• ASIST stands for Applied Suicide Intervention Skills Training and is
a 2-day workshop for professionals and non-professionals.
• ASIST complements safeTALK because persons who are identified
by suicide alert helpers receive the first aid intervention they need.
Beginning with a full exploration of caregiver attitudes, ASIST is
highly interactive and participatory. Over ½ of the workshop
involves working with suicide intervention simulations.
• ASIST participants receive workbook, prompter card, sticker, suicide
intervention handbook, and National Suicide Lifeline card.
• Workshop participant costs vary by location ($50-300). They often
offer 15 CEUs. 5-day Training for Trainers is around $2600.
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www.livingworks.net
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Don’t Do This
Things to avoid when working with at-risk students
– Take an ‘Us vs. Them’ approach
– Think issues are “resolved” like conduct cases –
conditions change over time
– Let FERPA/HIPAA and confidentiality law limit your
communications unnecessarily
– Adopt a ‘no parents’ approach
– Let students with mental health conditions ‘off the
hook’ when they violate a conduct code
– Coerce students into a voluntary leave
– Stick your head in the sand and hope you don’t see
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these situations
Do This
Things to do when working with at-risk students
– Don’t be afraid of conversations
– Empower and support the faculty and staff with
whom the student has a relationship
– Involve parents/support early and often
– Assist and support students through medical
withdrawal options (academics, tuition, support)
– Create clear policies that show care for students
– Ensure campus leadership, legal counsel, and the
front line subject matter experts are on the same
page
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Questions?
Check out:
www.studentaffairsenews.com
Presentation designed by:
Dr. Brian VanBrunt