Policy Page: The Law Doesn’t Require a Policy;
Should We Have One?
By Maryam BrotineIn August 2019, the Illinois General Assembly passed Public Act 101-455, requiring all school districts to “implement a threat assessment procedure that may be part of a school board policy on targeted school violence prevention.” Notably, the law does not require boards to adopt a policy on targeted school violence prevention — the procedure just may be part of such a policy. Should a school board, as a best practice, have a policy governing this required procedure? If so, why?
To answer this question (for this case study and other situations as well), start by looking to IASB’s bedrock, the Foundational Principles of Effective Governance, and considering why boards have policies in the first place.
The Purpose of Board Policies
Foundational Principle 1 states that the board clarifies the district purpose. As its primary task, the board continually defines, articulates, and re-defines district ends. In effective school districts, every part of the organization is aligned with the ends articulated by the school board in written board policy. In other words, the board policy manual is the school district’s bedrock — or foundation — or any other synonym you can find in a thesaurus!
This brings us to our next inquiry: What ends are served by a targeted school violence prevention policy that is implemented through a threat assessment procedure? Subscribers to IASB’s Policy Reference Education Subscription Service (PRESS) will find one example of applicable district ends articulated in sample board policy 4:190, Targeted School Violence Prevention Program, which begins with this statement:
Threats and acts of targeted school violence harm the District’s environment and school community, diminishing students’ ability to learn and a school’s ability to educate. Providing students and staff with access to a safe and secure District environment is an important Board goal.
To better understand this concept, let’s consider how policies and procedures work together.
How Policies and Procedures Work Together
Subscribers to PRESS will recognize the following descriptions, which appear in every PRESS issue:
Policy
The board develops policies with input from various sources like district administrators, the board attorney, and PRESS materials. The board then formally adopts the policies, often after more than one consideration.
Administrative Procedures
Administrative procedures are developed by the superintendent, administrators, and/or other district staff members. The staff develops the procedures that guide implementation of the policies. Administrative procedures are not adopted by the board, which allows the superintendent and staff the flexibility they need to keep the procedures current.
Procedures need to be flexible so that administrators can implement them in a practical manner that functions on a day-to-day basis. If there is no policy governing a procedure, then the board has no direct involvement in the subject matter at all. Without a policy, the board has 1) no mechanism by which to ensure that the procedure aligns with district ends, and 2) no means to monitor implementation of the procedure or to perform its oversight duties. In the case of threat assessment, adopting a policy that addresses targeted school violence prevention provides a way for boards to do both.
Who Should Be Involved in Policy Development?
The policy development process noted above states that policies are developed with input from various sources. Who, exactly, these “various sources” are is a key consideration and the answer will change depending on the policy being considered.
Developing a targeted school violence prevention policy presents a great opportunity for the board and the superintendent to examine all current policies, collective bargaining agreements, and administrative procedures relative to the issue. The board and superintendent should determine how local conditions, resources, and current practices will support the full implementation requirements of PA 101-455. Issues to consider in this case include, but are not limited to, the following:
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What does the district currently do to prevent targeted school violence?
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What is the district’s capacity to implement threat assessment teams? Can the district have teams in each school, as contemplated in sample board policy 4:190, which states that the district will establish building-level threat assessment teams? Or is a district-level or regional-level threat assessment team more feasible?
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How will a targeted school violence prevention program and threat assessment teams integrate with the district’s existing safety and security plans?
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Will the district need to revisit its relationship with local law enforcement, emergency response, mental health, and community service agencies to make threat assessment work?
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What resources, including professional development opportunities, does the board need to make available to staff to ensure the district can fully implement threat assessment procedures?
Once you determine the issues that need to be examined for policy development, you can identify additional “various sources” to consider involving in the process.
That’s the why, how, what, and who of a school board, as a best practice, having a policy governing a required procedure. The other usual questions — when and where — will be determined by your policy review cycle and are included in another Foundational Principal, number 5, and your board’s consistent monitoring of its compliance with board policies.