Behavioral Crisis Response

The purpose of Order 227 is to establish how the Behavioral Crisis Response Unit responds to people who may be experiencing a behavioral health crisis.

The Behavioral Crisis Response Unit, or BCRU, is part of the Patrol Division. The unit uses a co-responder model. Under this model, a specially trained police officer works with a civilian mental health clinician.

The officer is trained to respond to behavioral health emergencies using strategies intended to be compassionate, effective, and as minimally intrusive as possible. The clinician provides counseling, assists with de-escalation, and can connect the person with case management or other community services.

The policy identifies several situations that may involve a behavioral health crisis. These include suicidal or homicidal thoughts, hallucinations, delusions, paranoia, statements about self-harm or harming another person, and behavior that appears erratic or out of character.

BCRU officers can respond in several ways.

For a nonviolent crisis, a BCRU officer may respond directly. In other situations, a patrol officer may respond first and request BCRU after determining that behavioral health assistance may be useful.

The unit is available citywide while it is working. However, the policy states that BCRU squads work Monday through Friday from 7:00 a.m. until 3:00 p.m.

Order 227 also establishes examples of calls that are appropriate for BCRU assistance. These include calls involving a person who may benefit from behavioral health counseling, suicide-related calls that do not require immediate medical treatment, Baker Act calls involving juveniles at schools, and certain barricaded-person incidents.

The final portion of the policy addresses involuntary examination under the Baker Act.

Officers are instructed to use the criteria established by Florida law. The policy also recognizes that intellectual disabilities, neurological disorders, and developmental disorders are different from the mental illnesses normally addressed through the Baker Act.

However, the wording used to explain that distinction is not always precise.

The co-responder structure is one of the stronger parts of Order 227.

Instead of treating every behavioral health crisis as an ordinary police call, JSO assigns specially trained officers to work with mental health clinicians.

The clinician can provide counseling, assist with de-escalation, and offer connections to community-based services.

This gives the responding officer an alternative to relying only on enforcement, arrest, or involuntary examination.

The policy also states that BCRU officers are trained to respond in the least intrusive manner.

That is useful because a person experiencing a behavioral health crisis may need assistance without necessarily requiring arrest, physical restraint, or involuntary hospitalization.

The policy allows BCRU to respond directly to nonviolent incidents.

This means the specialized response does not always have to wait until another officer has already attempted to manage the situation.

BCRU can also assist with more complicated situations.

The policy allows BCRU involvement when a person has threatened suicide, when patrol is handling a juvenile Baker Act at a school, and when officers are communicating with a barricaded person who appears to be experiencing a behavioral health crisis.

This provides a way to use behavioral health training during incidents that could otherwise become more dangerous.

The Baker Act section also contains an important limitation.

The policy tells officers to use the criteria contained in Florida law rather than relying only on the person's unusual behavior or a diagnosis.

Florida Statute § 394.463 requires reason to believe that the person has a mental illness and, because of that mental illness, meets the additional statutory criteria for involuntary examination.

Florida law also excludes several conditions from the definition of mental illness when those conditions exist by themselves.

These include developmental disability and conditions manifested only by dementia, traumatic brain injury, intoxication, substance abuse, or antisocial behavior.

Therefore, Order 227 is correct to warn officers that conditions such as developmental disability or dementia should not automatically result in a Baker Act.

The first weakness is the limited availability of the unit.

BCRU works Monday through Friday from 7:00 a.m. until 3:00 p.m.

Order 227 does not explain what specialized behavioral health response is used after 3:00 p.m., overnight, or during weekends.

This leaves most hours of the week outside the BCRU schedule.

Florida operates Mobile Response Teams that are intended to provide behavioral health crisis response 24 hours a day throughout the year.

A specialized JSO unit does not necessarily need to operate 24 hours a day if another appropriate crisis service is available.

However, Order 227 does not explain what officers or dispatchers should do when BCRU is unavailable.

Because of this, the specialized response described in the policy depends heavily on the time and day of the crisis.

The second weakness involves the Baker Act language.

Order 227 states that an involuntary examination "may not be appropriate" when a person is only suffering from an intellectual disability, neurological disorder, or developmental disorder.

The wording should be more specific.

Under Florida law, the Baker Act requires a qualifying mental illness.

A developmental disability by itself does not satisfy that requirement.

The same general problem applies to dementia and several other excluded conditions.

A person may have both a developmental disability and a separate qualifying mental illness.

In that situation, the Baker Act may still apply.

However, the qualifying behavior must be connected to the mental illness rather than simply to the excluded condition.

The current wording could cause an officer to focus on dangerous behavior without first determining whether the required mental illness is actually present.

The examples used in the policy also contain an inaccurate classification.

Order 227 lists "speaking impairments" as an example of an intellectual disability.

A speech or communication impairment does not necessarily involve any intellectual disability.

A person can have difficulty speaking while having no impairment in intelligence, reasoning, understanding, or decision-making.

This distinction is important during a police encounter.

If difficulty communicating is interpreted as evidence of intellectual impairment, an officer may misunderstand the person's behavior or ability to comply.

The policy also defines behavioral health crisis broadly enough to include behavior that merely appears erratic or out of character.

A broad definition can help officers request assistance before a situation becomes more serious.

However, unusual behavior can result from many causes.

A person may have a medical condition, neurological disorder, developmental disability, communication disability, substance-related condition, trauma response, or another problem that appears similar to a psychiatric crisis.

Order 227 does not give officers much guidance for distinguishing those situations.

The policy also provides little information about accommodations for people with disabilities.

It specifically addresses autism, intellectual disability, neurological disorders, and communication-related conditions, but does not explain how officers should modify communication or procedures for those individuals.

Federal disability guidance requires law enforcement agencies to make reasonable modifications when necessary so that people with disabilities can receive equal access to police and emergency services.

Another weakness is that the policy does not clearly define the relationship between the police officer and the mental health clinician.

The clinician provides counseling, de-escalation, referrals, and behavioral health assistance.

However, Order 227 does not explain who normally leads the behavioral health assessment, how disagreements between the officer and clinician are resolved, or when the officer should allow the clinician to take the primary role after the immediate safety issue has been addressed.

Because of this, two BCRU teams could use the co-responder model differently while still following the written policy.

The decision to request BCRU assistance also depends heavily on the first patrol officer.

The policy states that BCRU may be requested when the patrol officer believes that a person may benefit from behavioral health counseling or other non-police services.

Therefore, the officer must first recognize the behavioral health issue.

Order 227 does not establish a dispatcher screening process or identify crisis calls that should automatically be routed to BCRU when the unit is available.

Federal behavioral health guidance recommends identifying crisis calls as early as possible so that the response can be selected before the first responder arrives.

The suicide-call criterion also needs clarification.

The policy states that BCRU assistance is appropriate when a person has threatened suicide and has not injured themselves badly enough to require immediate medical treatment and/or has not committed a felony.

A felony and a behavioral health crisis can occur at the same time.

The fact that a felony may have occurred can require continued police involvement, but it does not remove the need for behavioral health assistance.

The policy should separate those two questions.

Finally, Order 227 contains very little information about how JSO measures whether the program works.

The policy does not require collection or analysis of BCRU response times, clinician availability, voluntary service referrals, Baker Acts, arrests, uses of force, hospital transports, repeated crisis contacts, or other outcomes.

This makes it difficult to determine whether BCRU is reducing more intrusive police responses.

It also makes it difficult to determine whether the current Monday through Friday daytime schedule corresponds to the times when Jacksonville residents are actually experiencing behavioral health crises.

SAMHSA recommends measuring crisis-system information such as response time, presenting problem, disposition, law-enforcement involvement, involuntary intervention, restraint use, and diversion to behavioral health services.

The first change could be to establish a procedure for behavioral health crises that occur while BCRU is unavailable.

Order 227 could identify the Mobile Response Team or another approved behavioral health crisis provider that patrol officers and dispatchers should contact after BCRU hours.

The policy could also explain when law enforcement needs to remain involved and when the call can be transferred to a behavioral health provider.

Afterwards, JSO could compare the hours of BCRU operation with the actual times behavioral health calls are received.

If a substantial number of crisis calls occur during evenings, nights, or weekends, the staffing schedule could be adjusted or another response system could be formally incorporated into the policy.

The Baker Act section should also be rewritten.

Instead of stating that an involuntary examination "may not be appropriate" for someone whose behavior results only from a developmental, intellectual, or neurological condition, the policy could state that those conditions by themselves do not satisfy the Baker Act's mental-illness requirement.

The policy could then explain that a person may still qualify when a separate mental illness is present and the statutory criteria result from that mental illness.

The reference to speaking impairments as an example of intellectual disability should also be removed.

Communication disabilities could instead receive their own section.

That section could explain that difficulty speaking, understanding speech, processing instructions, or communicating in a typical manner does not establish intellectual disability.

The policy could then identify communication modifications that officers should consider.

The definition of behavioral health crisis could also be clarified.

Erratic or unusual behavior could remain a reason to request BCRU assistance.

However, the policy could state that unusual behavior is not itself proof of mental illness and that medical, neurological, developmental, communication, and substance-related causes should be considered.

The co-responder relationship should be described in more detail.

For example, the policy could state that once immediate safety concerns are controlled, the mental health clinician normally conducts the behavioral health assessment and recommends voluntary service options.

The officer could remain responsible for criminal enforcement and immediate safety decisions.

When the officer and clinician disagree about the appropriate response, the policy could require the reason for the final decision to be documented.

Dispatchers could also play a larger role.

Order 227 could identify call types or information that should result in BCRU notification when the unit is available.

This could include suicide-related calls, known behavioral health histories where legally available, repeated crisis contacts, requests from family members for behavioral health assistance, and other defined indicators.

The suicide-call language should also be revised.

The policy could state that felony conduct may require law enforcement involvement but does not automatically make behavioral health assistance inappropriate.

This would allow the criminal and clinical issues to be addressed separately.

Finally, JSO could establish an outcome review for BCRU.

The review could include the number and time of BCRU calls, whether a clinician responded, response time, voluntary referrals, Baker Acts, arrests, hospital transports, uses of force, injuries, repeat contacts, and other dispositions.

The same information could be reviewed by district, time of day, age, race, sex, disability information where lawfully available, and other relevant categories.

A difference would not establish improper conduct by itself.

The information would show whether the program is reaching the people it was created to serve and whether similar crisis calls are receiving similar responses.

Order 227 creates an alternative to treating every behavioral health crisis as a routine police encounter.

The policy places trained officers together with mental health clinicians and allows the team to provide counseling, de-escalation, referrals, and other services.

That structure gives JSO a way to respond to some crises without immediately relying on arrest or involuntary examination.

The main concern is that the written policy does not fully explain how that alternative operates.

The unit is available only during weekday daytime hours.

The policy does not identify the replacement service during the remaining hours.

Therefore, a person experiencing the same type of crisis may encounter a different system depending on when the call occurs.

The policy also depends heavily on the first patrol officer recognizing that behavioral health assistance is needed.

When the officer recognizes the issue, BCRU may become involved.

When the officer does not recognize it, Order 227 does not provide another automatic review point.

The Baker Act section creates a separate concern.

The policy recognizes that developmental, intellectual, and neurological conditions should not automatically result in involuntary examination.

However, the language does not clearly explain that Florida law requires a qualifying mental illness and that several of the listed conditions are specifically excluded when they exist by themselves.

That distinction affects whether a person can be taken into involuntary custody.

The policy also addresses people with disabilities without providing much guidance on accommodations or communication differences.

This is especially important because some of the behaviors officers may interpret as confusion, noncompliance, or psychiatric crisis can also result from autism, dementia, speech disabilities, neurological disorders, or other conditions.

Finally, Order 227 describes the program but does not require JSO to measure the results.

Without outcome data, it is difficult to determine how often BCRU prevents arrest, reduces Baker Act use, avoids force, connects people with voluntary services, or responds to repeat crises.

It is also difficult to determine whether the current work schedule matches the actual demand for behavioral health response.

Therefore, the next step for Order 227 is not simply to expand the description of BCRU.

The policy already explains what the unit is intended to do.

The larger need is to define when the specialized response is available, how it is selected, how the officer and clinician divide responsibility, how disability-related behavior is distinguished from mental illness, and how JSO determines whether the program is producing the outcomes it was created to produce.