What you should know about ‘Students of Concern’
Draft published on 10.03.23. Updated on 11.15.23
By Bowen Cho
There is a common but obscure reporting mechanism at many universities called Students of Concern (SoC) (example), which allows administrations to surveil a broad range of student behaviors under the lens of threat assessment and crisis intervention. These and similar reporting tools may increase targeting of student dissidents, students with legitimate grievances, and other students whom the university deems “undesirable,” including neurodivergent students and students experiencing distress. For example, students who have experienced mental health crises or suicidal ideation while on campus have been told by administrators that they have caused harm to the community and many have been silently pushed out of academia.
The historical origins of SoC coincide with two important developments in higher education during the last three decades: passage of the Americans with Disabilities Act (ADA) of 1990 and its amendment in 2008, which increased federal protection from discrimination for disabled students including those with psychiatric diagnoses, and concomitantly increased the number of disabled students pursuing college degrees; secondly, during this same time period, there was a drastic increase in enrollment of international students and U.S. veterans of the wars in Iraq and Afghanistan at U.S. campuses. These changing demographics in higher education raised concerns about how to “manage” a new generation of students whose values and behaviors might be at odds with the “traditional” expectations of the academy. The rapid growth of SoC on college campuses during the past decade has been a boon to industries that specialize in digital student case management though there have been few studies showing that these tools and interventions have actually been effective in supporting students.
Two private companies provide the majority of SoC services to hundreds of campuses across the US: Maxient and Symplicity. Maxient is a company with “1,300 client schools” (up from 1,100 since 2022) and claims to be “the most trusted provider for incident reporting and behavior records management,” including “conduct, Title IX, care and concern, academic integrity, and more.” Their website indicates that they receive 7,000 reports daily. Symplicity’s software is used by over 1,000 institutions to “quickly react to complaints and identify behavioral threats before an incident occurs.” There is no information on their website regarding what intermediary role(s) they might play in analyzing or sharing the information received about a student.
To give some sense of how rapidly SoC has been spreading in recent years, in 2020 I surveyed the top ranked public and private universities in each state (according to U.S. News) and found that 56 of 81 (69%) campuses had online reporting forms for Students of Concern. Of private institutions, 17 of 31 (55%) had online reporting, and of public institutions, 39 of 50 (78%) had online reporting. None of the Ivy League Schools at the time had Student of Concern pages. Only Cornell’s College of Architecture, Art, and Planning (AAP) had such a page.
This year I conducted another survey of the same set of universities and found that 70 of 81 (86%) now had Student of Concern pages, a 25% increase over three years. There was a 35% increase in SoC implementation among private universities, with 23 of 31 (74%) now using SoC tools, and a 21% increase among public universities, with 47 of 50 (94%) public universities using SoC. (For visual comparison, see Figure 1 below.) Three of the eight Ivies now have SoC pages. Some of the campuses that have implemented SoC reporting since 2020 include Dartmouth College, Johns Hopkins University, Princeton University, Rice University, Rutgers University, University of Illinois Urbana-Champaign, University of Notre Dame, and University of Virginia.
Figure 1. Number of private and public universities with online reporting forms in 2020 (left) and 2023 (right). Universities with SoC reporting tools are indicated in red. Click on image to enlarge.
Of the schools with online reporting forms, a few (around 11%) issue little to no guidance defining concerning behavior, and many sites instruct community members to report any behavior, “even if they are unsure.” Across the remaining schools with SoC reporting, there was great variation in what behaviors should be reported and little to no transparency in how support is offered to students experiencing distress. In some cases, reports are submitted directly to campus police or local law enforcement agencies. Frequently, reports are submitted to the Dean of Students Office and special Behavioral Threat Assessment & Management (BTAM) Committees formed by representatives from various campus departments including counseling services and campus police.
In several alarming instances, Students of Concern pages featured the slogan, “See something, say something,” which is the same slogan the NYC Metropolitan Transportation Authority created for its post-9/11 counter-terrorism campaign. Indeed, as work by the Stop LAPD Spying Coalition has uncovered, SoC and similar risk assessment and reporting tools have been adapted from the same DHS and FBI programs that primarily targeted Muslims after 9/11, and are built upon the same carceral and criminalizing logics, but in the guise of public health intervention. As Anu Joshi, deputy director at the ACLU, writes, “Experience has shown that this crowd-sourcing of surveillance ensures that it is not behavior or activity that is identified as suspicious, but rather skin color, religious markers, language, and other signs of difference.”
One of the common rationalizations for having SoC tools in place at universities is the fallacy that distress and mental illness are precursors to violence and radicalization, aka “red flags,” and therefore detecting and treating signs and symptoms may prevent the next mass shooting or terrorist attack. Many university guidelines explicitly identify Students of Concern as on a spectrum of low risk to high risk for violence. In fact, although some universities seem to maintain separate BTAM and SoC report forms, it is not uncommon to find both reports being sent to the Students of Concern teams. I corroborated this by filing public records requests for both types of reports, and receiving responses from the university records offices that separate records for BTAM and SoC could not be located.
The Higher Education Mental Health Alliance Project made this purported connection between Students of Concern and potential dangerousness explicit, when they defined Students of Concern as students with behavioral problems “that may both interfere with adequate and successful functioning that, if unaddressed, might lead to a dangerous outcome to the student or the community.”
An example of some behaviors that are considered suspicious:
- Contempt for authority
- Experiencing mental health issues or distress
- Being autistic
- Poor grades or absenteeism
- Showing anger or frustration
- Experiencing financial hardship
- Being an immigrant or “missing home”
- Being isolated or a loner
There is scant evidence to support claims that the above are reliable risk factors for criminality or violence, yet problematically, they retain a sort of face validity by appealing to folk notions of deviance and society’s willingness to scapegoat the most marginalized. A recent report by researchers at Australian National University found poor predictability of risk based on these factors, stating that “Without a strong theoretical and empirical basis for factor inclusion, it is not reasonable to anticipate that the instruments are able to predict their specified risk with anything other than chance.”
During the past decade, however, the media has consistently cited individuals’ mental health or disability when covering stories of violence, completely ignoring the contextual and ideological roots of violence including white supremacy, patriarchy, nationalism, militarism, and capitalism. One can reasonably conclude that these guidelines are political frameworks, serving to scapegoat already marginalized groups and to draw attention away from our collectively deteriorating material safety nets and social networks. In the addendum below (“Why Comics?”), I also allude to the striking similarities between the aforementioned factors and the Comics Code Authority’s historical restrictions on representation during the past century, illustrative of how the forms of censorship and repression remain fundamentally the same, but take on different targets with every new moral panic.
While threat assessment is built upon its own foundations of modern pseudo-scientific research created by psychiatrists like Stevan Weine in conjunction with law enforcement bureaus, as a form of pre-crime policing, threat assessment actually has long ableist roots stretching back to the eugenics movement of the early 20th century. A “psychopathic laboratory” in Chicago, for example, performed tests on incarcerated youths “to identify insanity before it had progeressed [sic] so far as to cause the victims to commit murder or other serious crimes.” (See Figure 2 above.) The goal was to establish such a system of testing across the U.S. such that “the insane men who suddenly commit murders could all have been identified as dangerously insane many years before their outbreaks… [which] would enable society to protect itself by preventing the individual from committing insane acts and by preventing the reproduction of insane stock.” How many disability rights advocates who defend or remain silent about SoC and other risk assessment tools actually grasp its deep roots in eugenics?
I consider SoC as part of a broader research question looking into the embedding of law enforcement and carceral practices within the health professions, i.e. the securitization of mental health, as evinced by policies like Prevent and Serenity Integrated Mentoring (SIM) in the UK, and CVE in the US, and which is concerning as a disabled person considering the history of law enforcement targeting and/or entrapping people with intellectual and psych disabilities. A 2018 study of threat assessment conducted in K-12 schools also found that Black students were referred 30% more often than white students.
There is little to no evidence that SoC reporting increases support for students, but anecdotally, we are beginning to learn more from people who have been coming forward to share their stories of being harmed. On this website, you can read some of those stories.
About the creator of this site
Bowen Cho is a neurodivergent, queer, and disabled scholar-activist. They are a 2023 Emerge Fellow with the Paul K. Longmore Institute on Disability at San Francisco State University. This project would not have been possible without their support.
Comics have always had a subversive potential about them. That’s why the Comics Code Authority was established in 1954. Throughout the 20th century, most of the major comic publishers “voluntarily” complied with CCA guidelines, which determined what stories could be told, and how characters could be represented. For example, LGBTQ characters and themes were not allowed to be depicted until the 1990s, and then we were mostly depicted as deviants and criminals. Even though the CCA’s power has evaporated in the 21st century, and although the comics industry is perhaps more influential in popular culture than ever, it still fails to live up to its subversive potential. For example, superheroes, as depicted in both mainstream film and print, often serve as proxies for agents of the state. Teams like the Justice League and S.H.I.E.L.D. are often heavily militarized, and work in cahoots with law enforcement and the government.