Threat Assessment Q&A: “Should Counseling Center Staff Conduct ‘Direct Threat’ or ‘Fitness for Duty’ Evaluations?”

By Gene Deisinger, PhD; Jeff Pollard, PhD & Marisa Randazzo, PhD

The question we received this week came from a training session on college/university threat assessment that we conducted in San Diego at the beginning of February 2011. A staff psychologist at a college counseling center asked us:  

Q: “Is it advisable for a college or university to have its counseling center psychologists or psychiatrists conduct "Fitness to Stay" or “Fitness for Re-entry” evaluations on students (both types are evaluations are similar to Fitness for Duty evaluations conducted on employees), and “Direct Threat” evaluations on students or employees”?  

A: While psychologists and psychiatrists on staff at college/university counseling centers may be qualified to conduct such assessments, we recommend that institutions think through several issues before asking this of their mental health professionals.

The first issue is that psychologists’ and psychiatrists’ training do not typically include the skills required for conducting such evaluations -- so colleges and universities should insure that the professional in question has demonstrated post-graduate training, supervised practice, and experience in conducting the evaluations. The professional standards for forensic evaluators or forensic psychologists/psychiatrists are good baselines for measuring the competence and/or setting out training/experience guidelines for someone whose position requires they conduct such evaluations. To be competent, examiners do not have to be certified at the forensic level; however they must possess the necessary training and hands-on experience.

The second issue is the impact that using counseling center staff as evaluators could have on the counseling center’s reputation on campus. Most counseling centers build their reputation and relationship with students as being a service for the students and may actively or implicitly have some advocacy role on behalf of student needs. Conducting evaluations that can negatively impact upon a student's status – that is, on a student’s ability to stay or enter the institution -- often raise concerns (on behalf of students and some faculty/staff) as to whether the center is a true support/advocate for students. While this can be addressed in terms of HOW the services are provided and how they are discussed in the community, it still raises concerns in which many centers choose not to involve themselves. Also, as most of these evaluations are mandated by the college or university as a contingency of enrollment, some centers are reluctant to involve themselves in mandated services. It would be fair to say that there is a good deal of controversy on this question as some professionals/centers do not view mandated services as consistent with counseling center philosophy and a few would go so far as to suggest it is unethical (a view we understand but do not necessarily hold).

Finally, when such evaluations are done internal to the institution - i.e., by a component of the university -- it raises a reasonable question as to the independence, autonomy, and objectivity of the evaluator. It may be reasonable for the person being evaluated to question findings presented by an internal evaluator because the evaluator is an employee or agent of the university and could be assumed (rightly or wrongly) to provide only conclusions that are in line with the university’s stance. Evaluations that are conducted by an external psychologist or psychiatrist make that argument of bias a bit harder to make, presuming the independent evaluator conducts a fair, thorough and objective evaluation.

The last issue we want to raise is that, with respect to high risk evaluations or ones in which there is a fair amount of ambiguity, we find it very helpful to have an objective, independent view from outside the university that either validates our views (from internal evaluations or the threat assessment process) or challenges misperceptions that we may have formed or provides information we could have overlooked. In essence, it can create a check and balance on the institution’s internal decision-making.

While none of these issues would legally prohibit a college or university from using someone on staff to conduct these evaluations, these concerns make it less ideal for an institution to do so internally. We want to be clear that our comments are only in regard to true assessment of dangerousness and fitness for duty evaluations (including fitness to stay and fitness for re-entry evaluations) and are not related to the types of evaluations that college health/counseling services provide routinely -- including intake/diagnostic screening and screening whether someone may benefit from involvement in mental health services -- for which counseling center staff members are highly competent and appropriate.