3-36 Workplace Violence- Threat Management Team Operating Procedures

• Effective date of this revision: August 30, 2021
• Contact for more information: Office of Civil Rights and Institutional Equity

1. SCOPE

Central Michigan University, consistent with its policy against Workplace Violence (“WPV”), takes the position that workplace violence, in any form, is prohibited at CMU and will be cause for disciplinary action up to and including dismissal. 

“Workplace violence,” as defined in CMU’s Workplace Violence policy involves an employee (faculty, staff, student employee) as either victim or alleged perpetrator of behaviors prohibited by the University’s Workplace Violence Policy while engaged in such behavior on the University’s campus, in off-campus locations leased or operated by the University or in any location while engaged in University business. “Workplace violence” situations involving a CMU student as alleged perpetrator will be addressed through the CMU Student Code of Conduct.

2. THREAT MANAGEMENT TEAM

The Threat Management Team (“TMT”) is composed of a core group of key university officials (see below) who have the responsibilities listed below. The TMT will handle all matters brought to its attention with due regard for the confidentiality and privacy rights of the parties involved in the incident. There is also a supplemental team of individuals who may be contacted as appropriate. The TMT is responsible for:

• Interpreting, reviewing, implementing and monitoring the WPV Policy.
• Reviewing reported university WPV incidents.
• Reviewing WPV investigative reports, and approving or revising recommended actions.
• Managing current and post-incident operations and trauma care, if necessary.
• Coordinating educational and training efforts on recognizing WPV signs, providing effective responses, dealing with post-incident coping mechanisms, improving reporting processes and such other related matters as determined appropriate by the TMT.

3. THREAT MANAGEMENT TEAM COMPOSITION 

*Primary contacts may appoint designees as necessary and appropriate.

4. INCIDENT REPORTING - WPV incidents shall be reported as follows

a. If the situation is perceived to present immediate danger, and/or if there are any weapons visible or implied, Call 911 (or military/local police, if off-campus). 

b. For situations not requiring immediate police involvement, contact any of the following intake offices: 

c. The intake office receiving the call will refer the incident to the appropriate intake office for follow up (see Table 3).

d. A supervisor who observes or receives notice or information about an actual or potential WPV incident in progress should:

1. take immediate and appropriate action to halt, diffuse or de-escalate the situation as long as it does not lead to a risk of personal harm; and
2. immediately report the matter to any of the intake offices noted above

5. INVESTIGATION AND FOLLOW UP

a. Initial Notice – Upon being notified of an allegation of workplace violence, a representative in the appropriate intake office will act as Field Investigator and will:

1. If necessary, take immediate and appropriate action to halt, diffuse or de-escalate the situation as warranted by the circumstances. Individuals are strongly encouraged to contact the Field Investigator immediately if threatening or violent behavior is repeated at any time following the initial report.
2. Quickly develop sufficient information from the complainant to form a preliminary assessment as to whether or not the allegations presented, if true, may represent a violation of the University’s WPV policy.
3. Promptly notify the core TMT about the incident, including the Field Investigator’s preliminary assessment of the allegations and a recommendation to:

a. Dismiss the WPV complaint,

b. Refer the matter to another office (i.e. Employee Relations, Faculty Personnel Services, Affirmative Action) if the matter does not constitute WPV but does suggest a need for further action or

c. Initiate an investigation as a Workplace Violence incident (criminal investigations will be undertaken by the CMU Police Department or other appropriate agency having law enforcement jurisdiction in the matter).

b. Investigation – The Field Investigator will immediately coordinate the investigation of the WPV complaint/report and may:

1. Review the WPV database files to determine if the alleged perpetrator has been the subject of prior Threat/Incident Reports, and how similar incidents have been handled.
2. Review the alleged perpetrator’s personnel file to determine if any disciplinary action has been taken previously, and for what circumstances.
3. Inspect the location where the alleged incident occurred to seek evidence of the workplace violence incident.
4. Recommend to TMT Chair that the CMU Threat Assessment Group conduct a formal threat assessment.
5. Interview the reporting individual, the victim, witnesses, the alleged perpetrator, the alleged perpetrator’s supervisor(s), and other individuals as deemed necessary, to obtain additional information.

c. Report

At the conclusion of the investigation, the Field Investigator will submit a report to the TMT Chair which summarizes investigative findings and recommends actions for response and follow up. The Field Investigator will also log the incident in the TMT database

d. Assessment & Response

1. Upon being notified of a WPV incident by the CMU Police Department or by a Field Investigator, the TMT may immediately convene to monitor the event (at the request of any member of the TMT), or may elect to defer convening a meeting of the TMT pending receipt of the Field Investigator’s report.
2. The TMT Core Team will review the Field Investigator’s report and recommendations. Based on that report, and from review of any other information or data deemed relevant by the TMT, the TMT will determine whether a substantial risk of harm to CMU persons or property exists and whether the incident is actionable or non-actionable.
3. If the WPV incident is determined to be non-actionable under the WPV policy, the case will be closed and the field investigator will notify the alleged perpetrator, the victim, the supervisors and others as deemed appropriate of the decision.
4. If the WPV incident is determined to be actionable, the TMT will work with the supervisor to determine the appropriate corrective action. To reach that determination, the TMT may consult with Supplemental TMT members in order to obtain additional information such as the University’s legal rights and responsibilities, police and security options/considerations, and/or psychological perspective and potential ramifications.
5. The TMT may adopt the Field Investigator’s recommendations as proposed, or may modify those recommendations as deemed appropriate by the Core TMT. The TMT will consider the need to conduct broader based action to address future incidents. Consequences to those who commit an actionable WPV offense could include, but are not limited to:

• Criminal charges.
• Dismissal.
• Suspension.
• Job Jeopardy Program (i.e., “last chance agreement”).
• Formal (written) reprimand.
• Referral to appropriate health care professionals and/or Employee Assistance Program (EAP).
• Banning from campus or parts of campus.

6. WPV EDUCATION AND TRAINING

a. A copy of the University’s WPV Policy will be made available to employees, either through print format or a University web page.

b. The TMT will coordinate WPV training for faculty and staff with those university offices responsible for conducting training for faculty and staff.

c. The TMT may make recommendations for WPV training topics and programs based on actual university experience and on applicable research into available programs and comparable best practices in industry generally, or higher education particularly.

Central Michigan University reserves the right to make exceptions to, modify or eliminate this policy and or its content. This document supersedes all previous policies, procedures or guidelines relative to this subject.