3.070 - Early Intervention System

Effective Date: 05/18/2015

3.070-POL

This policy applies to the use of the Early Intervention System. The Early Intervention System shall employ risk management strategies that are not punitive or disciplinary in nature.

The Early Intervention System is a key element in the SPD’s strategy to address at-risk behavior. Once an SPD employee exceeds a preset trigger of risk factors described below, an Early Intervention Assessment will be conducted. An assessment may also be conducted at the discretion of a supervisor as part of his or her ongoing duties to monitor employee conduct and maintain performance standards.

The progress of the employee will be carefully tracked, and the employee’s chain of command shall be personally responsible and accountable for the implementation of the individual program and such other steps as may be necessary to address any at-risk behavior, demonstrated indicators of stress, or training deficiencies, and ultimately achieve the professional goals set for the officer.

The system is separate from, and does not replace, the existing system of discipline for violations of policy. Department employees remain fully accountable for adhering to policy and performance standards. Nonetheless, the Early Intervention System seeks to identify and change at-risk behaviors before policy violations arise. The goal is to intervene and offer assistance by identifying and modifying possible problematic behaviors before they result in actions that are contrary to the mission and fundamental values of the Seattle Police Department, including its commitment to constitutional policing and upholding lawful, professional and ethical standards.

The Early Intervention System represents the Department’s commitment to coach and mentor its employees and to hold the entire chain of command accountable for addressing problematic behavior and managing risk to officers and the public.

The system is designed to support the employee through mentoring and coaching by supervisors. The use of the Early Intervention System provides employees:

* Training/Education

* Job performance feedback

* Other pathways to improve performance

* Consistent oversight and supervision

* A clear message to officers and civilian employees that the Department has resources available to assist them in meeting expectations.

Except as required by law, contract, or policy, information relating to the Early Intervention System shall be considered confidential and is not to be shared with persons not having access to the Early Intervention System. Violations of this policy may result in discipline.

Definitions:

1. Assessment Report: A form used to document the assessment conducted for an employee who has either reached the threshold criteria or who has been referred for a discretionary assessment.

2. Early Intervention Alert: Electronic pathway by which the assessment flows up the chain of command to the Performance Review Committee, and back. Each EIA has a tracking number.

3. Early Intervention Mentoring Plan: A strategy developed by an employee’s chain of command to intervene and offer assistance to the employee so that he or she will be able to uphold lawful, professional and ethical standards. A mentoring plan contains the following:

- Issue(s) to be addressed

- Method/action plan for addressing the issue(s)

- Timeline for completion of the mentoring plan

- Follow-up actions to be taken

4. Mandatory Training: Firearms qualifications and any other training designated as mandatory by the Captain of the Education & Training Section.

5. Status Report: Biweekly report used to document actions and training taken during the review period.

3.070-POL-1 Oversight of the Early Intervention System

1. Sergeants, Managers and Commanders Are Required to Review the Early Intervention Criteria Thresholds of the Employees They Supervise at Least Once Weekly

Section chains of command will be responsible for ensuring that all levels of supervision utilize the IAPro software for this purpose. If there is follow-up action based on this weekly review, the supervisor or commander shall document that in the PAS (Performance Appraisal System.).

Additionally, the Early Intervention Coordinator will provide section captains and civilian managers with monthly updates of the Early Intervention criteria thresholds related to the employees under their command.

2. Sergeants, Commanders and Civilian Supervisors Are Required to Initiate an Early Intervention Assessment (“EIA”) of any Employee they Supervise that Meets Criteria Thresholds

If an employee meets Early Intervention Criteria Assessment Thresholds, the employee’s supervisor will conduct an Early Intervention Assessment.

The EIA includes reviewing the Early Intervention Criteria thresholds and promptly notifying the affected employee if he or she has met any performance thresholds and affording the employee an opportunity to identify any errors in the data. If the information in the EIS is accurate, the sergeant, commander, or civilian supervisor must also review at least the last two performance evaluations in the PAS, documentation relating to the underlying incident(s) reflected in the EIS indicator, and any additional information that would be relevant to the identified performance issues.

3. A Sergeant, Commander or Civilian Supervisor May, in Conjunction with Their Chain of Command, Contact the Early Intervention Coordinator to Initiate the EIS and Assign a Discretionary Assessment to That Chain of Command

For example, if a supervisor notices potentially problematic behavior by an officer that should be addressed formally, they may initiate a formal Assessment even if an EIS threshold has not yet been met.

The Department recognizes that supervisors of all levels must be proactive in guiding the performance of employees under their command. Supervisors are encouraged to address any potentially problematic behavior or performance prior to the Early Intervention System being activated.

4. Upon Having an Officer Transfer into His or Her Squad or Unit of Command, a Sergeant or Commander Shall Review the Early Intervention Criteria Thresholds of That Employee, and Will Document Having Done So via the Performance Appraisal System

5. Utilizing IAPro Software, Employees Will Have Access to Their Current Standing Regarding Early Intervention Criteria Thresholds Levels

Employees may view a display of their performance data contained in IAPro by logging into that system, and may obtain their past EIS Review Report(s)/ Early Intervention Assessment(s) by making a request to the Director of Human Resources via their chain of command.

If an employee believes at any time that Early Intervention data is inaccurate, he or she should immediately notify his or her immediate supervisor or commander. The employee will then provide written notice (e-mail or memo) of his or her request for correction to the Early Intervention Coordinator in Human Resources via the chain of command. Any proposed corrections to the data are subject to review by the Performance Review Committee, the employee’s chain of command and the relevant bureau chief. The Director of Human Resources will make the final decision as to whether to modify early intervention data.

Corrections shall be documented fully in IAPro so that the Department maintains a reliable audit trail regarding data entry and corrections.

6. After Receipt of the Completed Early Intervention Assessment, the Section Captain or Director Shall Create a Mentoring Plan for the Employee, if Appropriate

If the section captain or director decides an Early Intervention Mentoring Plan is needed, he or she may recommend a specific review period. The review period shall continue until the employee’s chain of command provides the Performance Review Committee and the concerned Bureau Chief with satisfactory written assurances in the form of EIS Status Reports. These shall indicate that the officer or civilian employee has successfully completed the mentoring plan and his or her current performance is consistent with the lawful, professional and ethical standards of the Department. If possible, Early Intervention should be achieved in six months or less.

Any decision not to place the officer in Early Intervention will be documented, justified, and fully articulated in the narrative portion of the Assessment Form, which will then be attached to the IAPro Alert. The decision not to place an employee on an Early Intervention Mentoring Plan is subject to the approval of the Performance Review Committee and the relevant Assistant Chief.

7. Via the Early Intervention Coordinator, the Captain or Director Will Forward Their Recommendation of Whether to Put the Employee on an Early Intervention Mentoring Plan to the Performance Review Committee

The committee will review completed Assessments and Early Intervention Mentoring Plans to ensure Department-wide uniformity and consistency with SPD goals.

The committee may reject such Assessments and Early Intervention Mentoring Plans if they are inadequate, do not provide for uniformity and consistency in the treatment of similarly-situated officers, or otherwise appear inconsistent with the goals of the Early Intervention System.

8. The Performance Review Committee Will Monitor the Early Intervention System

The committee will comprise of stakeholders within SPD, to include:

* Chief's designee

* Human Resources Director or designee

* Representative from the Patrol Operations Bureau

* Representative from the Audit, Policy & Research Section (APRS)

* Representative from the Education & Training Section (ETS)

* Early Intervention Coordinator

* A representative of the City Attorney’s Office, if requested by the PRC

The committee shall meet monthly. The committee’s responsibility is to ensure Department-wide consistency and uniformity in the implementation of the Early Intervention System. The committee is further responsible for determining whether the performance assessments and proposed Early Intervention Mentoring Plans are adequate to address concerns about any at-risk behavior, demonstrated indicators of stress, or training deficiencies, and to provide the employee with the tools and support necessary to ensure that he or she adheres to Department policy and the lawful, professional and ethical standards of the Department. The committee will be responsible for reviewing and adjusting, where appropriate, the threshold levels of the Early Intervention indicator criteria. New indicator criteria will also be considered when and if appropriate. The committee’s recommendations for adjusting/changing indicator thresholds will be subject to approval from the Chief of Police.

The Early Intervention Coordinator will be responsible for scheduling meetings of the committee.

The Early Intervention Coordinator will be responsible for assisting commands with their use of the applicable Department computer software, including training of supervisors in its use.

9. The Committee Will Forward the Assessment and Early Intervention Mentoring Plan to the Appropriate Bureau Chief for Final Approval

10. The Early Intervention Coordinator Maintains Resources and Supervisor’s Toolkit for the Early Intervention System

11. The Early Intervention Coordinator Monitors Information Related to Certain Precinct-Level Activity

See 3.070-TSK-1 Early Intervention Coordinator’s Role in Creating, Implementing and Completing an Early Intervention Mentoring Plan.

12. Documentation of Early Intervention Threshold Criteria in the Yearly Performance Appraisal Evaluation

Sergeants and first-line supervisors will document Early Intervention threshold indicator activity in the Performance Appraisal System. See Seattle Police Manual Section 2.070-Performance Evaluation. Section Captains and civilian managers shall monitor supervisors’ use of the EIS software in the Performance Appraisal System.

EIS Timetable

3.070-POL-2 Administration of the Early Intervention System for Employees

1. Threshold Levels Initiate an Early Intervention Assessment

When the below criteria thresholds are met, an Early Intervention Assessment will be conducted for the involved employee. These thresholds are subject to revision, given the needs of the Department, after the consideration of the Performance Review Committee and the approval of the Chief of Police. The threshold time periods exist on a rolling basis.

* E.g., if an officer gets in two vehicle pursuits within any period of six consecutive months, he or she has met the threshold level.

Indicator CriteriaThreshold Levels
A. Chain-of-command recommendations / discretionary assessments Each will be reviewed
B. Use-of-force (Type I) Reaching the top 1% of officers who have used force investigated at Type I within 6 months
C. Use of-force (Type II) Reaching the top 5% of officers who have used force investigated at Type II within 6 months
D. Use-of-force (Type III) Reaching the top 5% of officers who have used force investigated at Type III within 6 months
E. Vehicle collisions 2 Department vehicle collisions within 12 months
F. Receipt of OPA complaints / Supervisory Action 3 complaints within 12 months
G. Receipt of OPA complaints / Frontline Investigation 3 complaints within 12 months
H. Receipt of OPA complaints / OPA Investigation 3 complaints within 12 months
I. Receipt of EEO complaints 2 complaints within 12 months
J. Named in police actions claims or Police action lawsuit against the City 2 within 24 months
K. Vehicle pursuits 2 within 6 months
L. Unexcused failure to appear in mandatory training* 1 within 12 months
M. K9 apprehension-bite ratio More than 15% K-9 apprehension bite ratio in a 12 month period
N. Officer-involved shooting Single incident threshold

Additionally, an Early Intervention Assessment will be conducted at the aggregate level when an employee has a total of six (6) indicators between A – M during any six-month window when the employee is not on a mentoring plan.

An employee’s sergeant first-line supervisor shall meet with the involved employee and discuss relevant factors, up to and including an Early Intervention Plan. The chain of command has the ability to include others in this discussion, as deemed necessary.

2. When an Officer or Civilian Employee Under an Early Intervention Mentoring Plan Has Additional Early Intervention Threshold Indicator Activity, That Employee’s Lieutenant or Manager Will Review Any Further Early Intervention Threshold Indicator Activity

If an officer currently the subject of an Early Intervention Mentoring Plan has additional Early Intervention System activity, the employee’s lieutenant will review the new event and submit to the captain, via the status report, a written recommendation regarding whether the original Early Intervention Mentoring Plan should be revised. Additional entries to the Early Intervention Mentoring Plan due to additional triggers are reviewed by the chain-of-command and the Performance Review Committee.

3. First-line Supervisors of Employees Designated for Early Intervention Assessments or Mentoring Plans Shall Coach and Mentor Employees About Issues and Behaviors That Indicate Possible Problematic Behavior

First-line supervisors shall carry out strategies to correct and modify the behaviors identified by the Early Intervention System. Based on each circumstance, performance mentoring of employees may include, without limitation:

* Regular and consistent conversations with employees about issues and incidents that affect behavior and performance.

* Sergeant ride-alongs with employees

* Sergeant accompaniment of employees on at least four calls/traffic stops/citizen contacts per work week.

* After action debriefs of significant events, arrests or other incidents that are an indicator criteria for the Early Intervention System.

* Review of the employee’s training history and possible referral to the Education and Training Section for additional training and/or assistance.

* Identifying and supporting positive behaviors.

Debrief Exceptions: Designated Type III Use-of-Force incidents, firearms discharges, and any open OPA complaint cannot be discussed in detail, per labor agreements and Department policy. Sergeants may discuss general issues and best practices with the involved officers after that officer has given a statement and has been interviewed by OPA.

3.070-TSK-1 Early Intervention Coordinator’s Role in Creating, Implementing and Completing an Early Intervention Mentoring Plan

The Early Intervention Coordinator:

1. Monitors information related to certain precinct-level activity:

* Uses of force

* Numbers of individual employees who have triggered Early Intervention Assessments

* Frequency of Early Intervention Assessments generated by employees assigned to specific supervisors in order to identify supervisors in need of additional skills and training.

2. Identifies employee who has met the criteria for an Early Intervention Assessment.

3. Verifies that the Early Intervention threshold criteria record for the identified employee is accurate and not the result of a system or human error. If a there is a question about accuracy, the Early Intervention Coordinator will consult with the Human Resources chain of command and the employee’s chain of command, to determine whether or not an Early Intervention Assessment should proceed.

4. Notifies, within three days, the employee’s chain of command, to include section captain or directors, that an Early Intervention Assessment needs to be completed, if the early intervention threshold criteria record is accurate.

5. Provides assistance and acts as a resource to personnel involved in the early intervention process.

6. Receives and reviews the completed Early Intervention Assessment from the section captain or director. Advises the committee of possible inadequacies and issues of non-uniformity.

7. Compiles Early Intervention Assessments from across the Department for the committee.

8. Forwards the completed Early Intervention Mentoring Plan, Assessment and Status Reports received from the section captain or director to the PRC, at least one week prior to the next committee meeting.

Upon being advised by a supervisor that he or she would like to conduct an EIA for an officer or civilian employee who has not met a threshold, the Early Intervention Coordinator shall create an EI Alert and provide it to the supervisor, commander or civilian manager. This initiates the same set of tasks for the employee’s chain of command as an EIA that is triggered by the threshold criteria.

3.070-TSK-2 Sergeant/First-Line Supervisor’s Role in Creating, Implementing and Completing an Early Intervention Assessment/Early Intervention Mentoring Plan

Upon notice that one of the employees under his or her supervision has triggered an Early Intervention Assessment, or upon deciding to conduct a discretionary assessment, the sergeant/first-line supervisor:

1. Obtains documentation relevant to the triggering incident(s).

* Such documentation may include GO Reports, use-of-force reports, OPA/EEO complaints and collision reports.

2. Reviews documentation relating to the triggering incident. The scope of the review must be thorough enough to identify factual circumstances surrounding the initiation, progression, and conclusion of the triggering incident(s) and to enable the supervisor to identify potential issues.

If a triggering incident has already gone through a separate administrative review (e.g., force review, OPA, collision review), the supervisor should be aware of the outcome of such review and should verify that the employee has followed through with any training recommendations or requirements or is scheduled to do so.

3. Reviews performance information contained in Blue Team (and/or IAPro) and the Performance Appraisal System (“PAS”),looking for repeated issues and/or related trends.

In BlueTeam/IAPro, the sergeant reviews information contained in all indicator criteria areas. See 3.070-POL-2.

In PAS, the sergeant reviews at minimum: (a) the last two performance evaluations, and (b) any documentation relating to performance that has occurred between the last evaluation and the date of the assessment.

When reviewing both BlueTeam/IAPro and PAS, the scope of the review must be thorough enough to identify factual circumstances surrounding the initiation, progression, and conclusion of the incident(s) and to enable the supervisor to identify potential issues.

4. Considers any additional factors that may be relevant to the identified performance issue(s) or that might be impacting an employee’s performance.

Such factors may include an employee’s work history with the Department, secondary employment history, or EIS-related information beyond the triggering incidents (e.g., any prior EI Assessments or prior EI Mentoring Plans).

The review of these factors must be thorough enough to identify factual circumstances surrounding the initiation, progression, and conclusion of those incident(s) an to enable the supervisor to identify potential issues. The supervisor should become aware of the outcome of triggering incidents that have already gone through separate review and consider whether the employee has followed through with any training recommendations or requirements or is scheduled to do so.

5. Promptly notifies the affected employee if he or she has met any performance thresholds and affording the employee an opportunity to identify any errors in the data.

6. Meets with employee and offers the employee an opportunity to explain the potentially problematic behaviors.

7. Prior to completing an assessment, accompanies/observes the employee in work-related activity whenever possible.

8. Considers referrals to the Education & Training Section, the Employee Assistance Program (EAP) and/or Critical Incident Stress Management (CISM) Team. These alternatives may be part of the Early Intervention Mentoring Plan but are not substitutes for it.

9. Completes and submits, within 14 days of notice, an Early Intervention Assessment and, if appropriate, proposed Mentoring Plan through the supervisory chain. A proposed Mentoring Plan must identify specific performance issues to be addressed, identify specific methods/trainings that will be utilized to address the identified performance issues, and identify specific time frames for completing assigned tasks or training, and identify the chain of command responsibilities in ensuring the performance issues are addressed and corrected by involved employee, to include completion of bi-weekly status reports. If a training plan is not recommended, the supervisor shall thoroughly document the reasons for such decision.

10. If Early Intervention Mentoring Plan is approved, coaches and mentors the affected employee so as to end the potentially problematic behavior and improve performance on a continuing basis, using strategies identified in Section 3.070-POL-2.3

11. Utilizes the status report to document actions/training taken.

12. Modifies, in conjunction with the chain of command, the Early Intervention Mentoring Plan as needed.

13. Submits an Early Intervention Status Report on a twice monthly basis to their supervisory chain for review and concurrence.

14. Upon completion of designated Review Period, documents and recommends on the status report whether or not affected employee has participated in and made progress in the designated training/coaching.

3.070-TSK-3 Lieutenant/Manager’s Role in Creating, Implementing and Completing an Early Intervention Assessment/Early Intervention Mentoring Plan

Upon notice that one of the employees under his or her command triggers an Early Intervention Assessment, or that a sergeant/first-line supervisor has decided to initiate a discretionary assessment, the lieutenant/manager:

1. Reviews the circumstances that triggered the EIA.

2. Ensures that the employee’s sergeant/first-line supervisor is aware of and will be responsible for the EIA.

3. Reviews Early Intervention Assessment and proposed Mentoring Plan developed by sergeant/first-line supervisor for completeness and appropriateness, as described in Section 3.070-TSK-2.

4. Directs corrections, modifications, and/or additions to the Early Intervention Assessment and/or Mentoring Plan when needed.

5. Recommends whether or not employee should be assigned to the Early Intervention Program via the proposed Early Intervention Mentoring Plan.

6. Submits, within three days of receipt from the sergeant/first-line supervisor, the completed Early Intervention Assessment and proposed Mentoring Plan to the section captain/director.

7. Reviews Early Intervention Status Reports for the employee and documents their observations on the EI Alert.

8. Specifies on the Early Intervention Status Report and at the completion of designated Review Period, whether the employee should be removed from Early Intervention Program.

3.070-TSK-4 Section Captain/Director’s Role in Creating, Implementing and Completing an Early Intervention Assessment/Early Intervention Mentoring Plan

Upon notice that one of the employees under his or her command triggers an Early Intervention Assessment, or that a sergeant/first-line supervisor has decided to initiate a discretionary assessment, the captain/director:

1. Reviews the factors and circumstances that led to the EIA.

2. Ensures that the employee’s lieutenant and sergeant/manager and first-line supervisor are aware of and will be responsible for the EIA.

3. Reviews assessments and proposed mentoring plans for completeness, appropriateness and effectiveness with the goal of reducing problematic behavior and upholding lawful, professional and ethical standards.

4. Determines whether or not a proposed Early Intervention Mentoring Plan appropriate based on completed EIA and if so, establishes a timeframe for implementing Early Intervention Plan timeframe.

5. Forwards, via IAPro, completed Early Intervention Assessment/ Early Intervention Mentoring Plan within seven days of receipt to the Early Intervention Coordinator in Human Resources.

6. Implements and oversees Early Intervention Plan, upon approval by bureau chief.

7. Reviews completed Early Intervention Status Reports forwarded by lieutenant/manager for completeness and appropriateness and documents having done so in the comments field of the EI Alert.

8. Designates, if appropriate, that the affected employee has completed the designated Early Intervention Mentoring Plan review period and should be removed from the Early Intervention Program or; that the Early Intervention Mentoring Plan will be extended for another specified time period.

3.070-TSK-5 Performance Review Committee’s Role in Creating, Implementing and Completing an Early Intervention Assessment/Early Intervention Mentoring Plan

The Performance Review Committee:

1. Reviews certain precinct-level activity:

* Whether executives are holding Captains accountable for managing the risk of police misconduct in their units.

* Whether the Lieutenants/managers or captains/directors or both are adequately holding sergeants/first-line supervisors accountable for their supervision of officers/civilian employees under their command.

* Whether the employee’s immediate supervisor has adequately overseen the employee’s performance in the past and is doing so currently.

2. Reviews each Early Intervention Assessment/ Early Intervention Mentoring Plan/status report against Department policy to ensure consistency across Department.

3. Determines whether Early Intervention Assessment/ Early Intervention Mentoring Plan/status reports meet department’s goals of intervening and offering assistance to employees.

4. Forwards, within seven days of the monthly meeting, Early Intervention Assessment/ Early Intervention Mentoring Plan/status reports with their recommendations to appropriate bureau chief for final approval.

3.070-TSK-6 Bureau Chief’s Role in Creating, Implementing and Completing an Early Intervention Assessment/Early Intervention Mentoring Plan

When one of the employees under his or her supervision triggers an Early Intervention Assessment, either by way of a chain-of-command recommendation or by crossing one or more thresholds, the bureau chief:

1. Reviews initial recommendations for action developed by affected employee’s chain of command and the PRC.

2. Determines whether Early Intervention Assessment/ Early Intervention Mentoring Plan is consistent with SPD policy and the goals of intervening and offering assistance to employees so that they will be able to uphold lawful, professional and ethical standards.

3. Approves, within five days of receipt, the Early Intervention Assessment/ Early Intervention Mentoring Plan, as appropriate.

4. Reviews completed Early Intervention Mentoring Plan Status Reports prepared by subordinates.

5. Designates final disposition of Early Intervention Mentoring Plan as completed or directs additional actions.