Many Title IX coordinators, directors of disability services, and conduct officers serve on Behavioral Intervention Teams (BITs) or Threat Assessment Teams (TATs), and their roles bring valuable perspectives. Sometimes, their roles can create uncertainty about information sharing.
A common question we receive is whether it is appropriate to share information obtained through disability services, particularly psychological evaluations or diagnostic documentation, that may be relevant to behavioral or threat assessment cases. Understanding when and how that information can be used is essential to balancing privacy protections, role clarity, and campus safety.
Question: We have a student who has submitted multiple psychological evaluations from different providers, each with differing diagnoses. This same student has been referred to BIT for threatening and aggressive behavior and is self-reporting that his disability is contributing to his behavior. Can (and should) information obtained through disability services be shared with the BIT?
Answer: In most cases, yes. Once information is received and maintained by disability services, it becomes part of the institution’s education record and falls under FERPA, not HIPAA. This means the information can be shared internally with other officials who have a legitimate educational need to know.
When a team assesses the risk of harm to self or others, the need-to-know standard is commonly met. The BIT or TAT arguably has one of the most compelling legitimate interests on campus: access to relevant information to make a sound, evidence-based assessment.
This does not mean the disability services information should be shared indiscriminately or appended wholesale to multiple records. It is often wise to consult legal counsel on this access question when it arises, unless an emergency is present. Practitioners should share what is necessary and relevant to support the team’s assessment. For instance, if a pattern emerges across multiple evaluations, such as inconsistent diagnoses, concerning or risky behaviors or symptoms, or a clear escalation of behavioral risk, that synthesis can be summarized for the team rather than distributing full evaluation reports.
Role Clarity
For disability services professionals who are also BIT members, it’s common to serve as part of the team’s inner circle. Title IX coordinators are often considered part of the inner or middle circle of team membership. NABITA’s Standards for BITs explains this distinction in more detail in Standard 5: Team Membership, and this topic is covered in NABITA’s certification course, BIT Standards and Best Practices.
Best Practices for Documentation
Before deciding to include the medical documentation from disability services records—or even portions of the medical documentation—in the student’s BIT file, consider whether this is the best way to capture the information relevant to the BIT. Full psychological evaluations or other medical assessments may contain sensitive and unnecessary medical data. A better practice may be to include:
- A summary of relevant findings (e.g., cognitive or emotional patterns that influence behavior).
- A note that multiple evaluations were reviewed and considered in the team’s assessment.
This approach supports transparency and due process without overexposing sensitive details. Sharing disability services information within a BIT or threat assessment context is appropriate when done responsibly, intentionally, and in accordance with FERPA. NABITA recommends teams act in the best interest of both the student and the community, balancing compassion, privacy, and safety in every case. The same is true for student conduct records, which may help a team to understand a pattern or address severity, and the same standards and practices discussed above apply.
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