A Coordinated Approach to Campus Safety: Bridging Clery, Title IX, and Behavioral Threat Assessment

Editor’s Note: In this article, the authors discuss the intersection of three campus safety paradigms that can and should work together in an intentional way. Importantly, the authors recognize that gendered harm and violence under the purview of Title IX are important considerations for community awareness and for behavioral threat assessment and management teams to be made aware of given the intersectional nature of gendered violence with other forms of violence. The authors recommend clear governance structures, information sharing protocols, cross-training, and the documentation of risk-based decisions for those assigned to each of these three pillars of campus safety. 

Just days after the Brown University shooting last December, in which a former student killed two undergraduates and wounded nine others inside a campus building, the U.S. Department of Education launched a review of Brown for potential violations of the Jeanne Clery Campus Safety Act. Assessing Brown’s Clery Act compliance and overall security preparedness provides a backdrop against which other higher education institutions may assess their own efforts to protect campus communities. Key programs and processes to keep campuses safe include not only those under the Clery Act, but also Title IX of the Education Amendments of 1972, and behavioral threat assessment and management programs. Approaching these measures synergistically strengthens prevention, response, and accountability in higher education.   

Below, we briefly explain each of these systems and then discuss the areas where they intersect.  

Understanding the Three Pillars  

1) The Clery Act 

The Clery Act requires postsecondary institutions to track and publicly report certain crimes, issue timely warnings for ongoing threats, and maintain daily crime logs. Clery also imposes reporting requirements concerning institutional policies and educational programs.  

But Clery is not merely a reporting law—its focus is transparency and community awareness. Compliance demands precise crime classification, coordination with campus security authorities, and sound judgment about when an incident presents a “serious or continuing threat.” Timely warning decisions often hinge on whether an alleged offender poses an ongoing danger. That determination significantly overlaps with Title IX and behavioral threat assessment processes.  

2) Title IX 

Title IX prohibits sex discrimination in educational programs receiving federal funds. Sex discrimination includes sexual harassment, sexual assault, dating violence, domestic violence, and stalking.  

Title IX centers on protecting complainants’ access to education, providing supportive measures, and ensuring equitable processes with due process protections for all parties.  

3) Behavioral Threat Assessment and Management (BTAM) 

BTAM is a multidisciplinary process designed to identify, assess, and manage cases in which an individual’s behavior indicates the potential for targeted violence. It is prevention-focused, not discipline-focused.  

Core members of threat assessment teams in higher education typically include representatives from campus security, student conduct/student affairs, and counseling. Participants may also include, among others, legal counsel and the Title IX officer. Sometimes referred to in higher education as Behavioral Intervention Teams, these groups help to centralize reporting, facilitate early intervention and needed supports, and ensure that cases do not “fall through the cracks.”   

Overlapping Behaviors

Many behaviors trigger obligations under multiple systems simultaneously; institutions should address these overlaps in their reporting and response procedures. Stalking may require Title IX action, Clery reporting, and a threat assessment and management process. Dating violence may require a Clery timely warning, a Title IX investigation, and attention from a BTAM team. Harassing conduct that falls below the criminal threshold could signal escalation risk, similarly warranting Title IX and BTAM consideration.   

A recent example of these convergences is notable in the case of Goncalves v. Washington State University, in which a WSU teaching assistant and graduate student murdered four students at the neighboring University of Idaho. WSU allegedly failed to follow its own BTAM process, despite having a team in place. The complaint also alleges that the perpetrator’s harassing behavior at WSU was so extreme and pervasive as to create Title IX liability by depriving multiple female students of the full benefits of the educational program. The allegations in this case demonstrate that coordination between Title IX compliance and BTAM processes is crucial for campus safety.  

Without coordination, responses can conflict, and misunderstandings can ensue about who is responsible for preventing harm. A coordinated approach keepsstakeholders informed and clearly allocates responsibilities. The Title IX office may prioritize confidentiality and supportive measures, while campus security assesses whether a Clery timely warning is required. A BTAM team has the capability to gather information about the person of concern from disparate sources, provide a rigorous threat assessment, and assume responsibility for regular follow-up and case management measures. These are not competing priorities. Instead, they must be harmonized through deliberate coordination.  

Supporting Survivors and Managing Risk During Ongoing Processes 

A critical intersection arises during Title IX investigations. When allegations involve stalking, threats, or escalating behavior, institutions must prioritize survivor safety while maintaining fair processes for all parties.  

BTAM can play a critical role here, both in assessing respondent risk and in developing plans that address community safety, including the needs of the Title IX complainant. While Title IX governs the grievance process, threat assessment teams evaluate ongoing risk. Both can result in recommendations for supportive and protective measures including: adjustments to housing or class schedules; no-contact directives; safety escorts for survivors; increased monitoring of respondents; and referrals to support services.  

Importantly, threat assessment is not a shortcut to discipline. BTAM addresses risk management in parallel with—not in place of—investigative processes.  

Building an Integrated Model

Security professionals in higher education can take several steps to align these systems effectively.  

Establish Clear Governance Structures 

Define roles and decision-making authority in clear written protocols, and disseminate those protocols to all stakeholders before high-pressure situations arise. Who determines when to issue timely warnings? Who sits on the threat assessment team? When is the Title IX Coordinator notified?   

Create Structured Information-Sharing Pathways 

Develop written guidance on when and how information flows between campus security personnel, the Title IX office, and BTAM teams, including FERPA boundaries and permissible disclosures in health and safety emergencies.  

Conduct Joint Training 

Cross-train personnel on Clery classifications, Title IX requirements,  best practices and compliance considerations in BTAM, trauma-informed response, and institutional reporting mechanisms. Shared language and shared understanding reduce friction and improve coordination, while ensuring survivors are treated with dignity and respect throughout the process.  

Document Risk-Based Decisions 

When institutions decide whether to issue a timely warning, to share otherwise confidential information, or to implement threat management measures, clear guidance for documentation of the decision process protects both the institution and the community.  

Focus on Prevention  

Clery and Title IX establish minimum legal requirements. BTAM expands the conversation to early identification and intervention. True prevention extends further—to campus culture, consent education, bystander intervention programs, and addressing the conditions that enable sexual violence. Institutions that treat compliance as the floor—not the ceiling—are better positioned to prevent harm.  

From Silos to Systems

The future of campus safety lies in integrating Clery, Title IX, and BTAM mandates and practices into a cohesive safety ecosystem. When aligned effectively, these systems create campuses where survivors and vulnerable individuals are supported, perpetrators are held accountable, and communities are safer, more equitable, and more resilient.  


VIOLENCE PREVENTION NOTICE: Warning signs often appear before violent acts. If someone you know makes general or specific threats, shows unusual interest in weapons, or fixates on previous violent incidents, you’re not overreacting by taking action. Ask direct questions and help them connect with professional support (or alert authorities if danger is immediate). Your intervention can prevent tragedy.

Mary Rohmiller has over two decades of experience at the intersection of civil rights, education law and policy, and constitutional law. Mary is a Partner in Potomac Law Group’s Education practice group. Her practice focuses on providing legal advice, counsel, analysis, and policy development to educational institutions and social impact organizations. Before joining PLG, she served at the U.S. Department of Education’s Office for Civil Rights, where she played a central role in developing federal Title IX policy and regulations.

Kelly Berkell serves as Executive Director of the Center on American Law and Extremism, a New York nonprofit organization, and a Senior Research Fellow at the Center on Terrorism, John Jay College of Criminal Justice, where she teaches courses on terrorism and homeland security. Kelly is also a Partner at Potomac Law Group, where she leads the firm’s Threat Assessment and Management practice. Kelly has developed guidance and training for practitioners on the legal and compliance considerations in preventing targeted violence. Her research has been published in outlets including the Harvard National Security Journal, the Journal for Deradicalization, and the Handbook of Terrorism Prevention and Preparedness from the International Centre for Counter-Terrorism – The Hague.

Related Articles

Latest Articles