The answer is, it depends. The question comes up at almost every one of our security training sessions. Honestly, there are both advantages and disadvantages of either option. Guns and Security: the Risks of Arming Security Officers in the December issue of Security Management (a publication of the security industry trade association, ASIS) discusses many of the issues that must be considered.
Each organization must carefully weigh the pluses and minuses themselves, as applied to their building, their constituencies and their culture. Since this decision could possibly affect your brand, your reputation and/or your liability, it is advisable to include your board of directors in the decision. If your organization is leaning towards armed security, we suggest four “best practices”:
- Hire any armed security guard on the basis of their experience, training and judgement rather than their weapon. If you hire e.g., an off-duty/retired law enforcement officer, you are hiring much more than their gun.
- Deploy armed guards as one element of a multi-layer security plan. If a determined intruder is targeting a specific institution, a solo guard (armed or not) may become the first, unfortunate target without any opportunity to even his/her weapon.
- Contract with an outside firm. Given the documented risks associated with armed guards (outlined in the Security Magazine article), consider contracting with an independent vendor and make sure that they are responsible for the supervision of armed guards, all aspects of the armed guard’s ongoing training and compliance with governmental training, licensing and other requirements.
- Discuss your decision with your insurer. Whether the armed guard is, or is not, your employee you may have some liability and/or named in any lawsuit. Make sure that your insurer knows about your decision and that your are appropriately and adequately covered. (n.b., Some institutions employ an outside security consultant to manage their employees. A discussion between the security consultant and the insurer may assuage the concerns raised by the insurer).
NYPD does have a Paid Detail Unit which provides officers to perform off-duty, uniformed security work within New York City for approximately $45/hour. Click here for more information and contact details. Of course, the above recommendations still apply.
|Quick tips: What should your guard(s) be doing?|
|Guards should not be merely uniformed potted plants adorning your lobby. Rather, they should be an important and active component of your overall security plan.
If you have a single guard, his/her logical priority is access control (see our suggestions on how to develop an access control policy here). At the same time, don’t lose sight of other important functions, including:
The security management industry calls instructions for guards, “post orders” which clearly outline the duties, responsibilities, and expectations of security guards. For example, your post orders should clearly set forth your access control policies and define the areas of your property that should be included in a walk-around and their time and frequency (e.g., upon arrival and upon returning from lunch).
The New York City Department of Citywide Administrative Services (DCAS) held its first meeting with schools yesterday. Applications for the School Security Guard Program are currently being accepted until November 1st for 2016-2017 school year. For questions related to the nonpublic school application process, it is really worth your while to check out the FAQ‘s. If you still have questions, contact Latesha Parks – email@example.com. We feel that DCAS has been making this process user-friendly.
Eligible schools. To be eligible to participate in the program, a school must meet the following:
- Must be New York City nonpublic school;
- Must be nonprofit;
- Have 300 or more students in any combination of grades Pre-K through twelfth grades only;
- Have been assigned a Basic Educational Date System (BEDS) code by the New York State Education Department (NYSED).
Eligible security guard companies. DCAS is working to establish a list of qualified security vendors. In order to receive reimbursements, schools will only be able to utilize firms that are on the qualified vendor list. Once a list is available, DCAS will notify schools of its availability via email or letter. The list will also be available on the DCAS website. Information about how security guard companies can apply to become qualified vendors can be found in the FAQ’s.
Contracts. One piece of advice. As a school you will contract directly with a qualified security vendor. You should make sure to stipulate in the contract that should the designated City funds become unavailable, that the school has the option to decide whether to continue or terminate the contract.(n.b., the law caps the expenditure at approximately $20 million, so there is a slight possibility that the funding might run out).
There will be up-dates – so check frequently with JCRC-NY and at the DCAS website.
Security Guard Reimbursement for Nonpublic Schools
Local Law 2 of 2016 authorizes the City of New York to reimburse qualifying nonpublic elementary and secondary schools for the cost of certain security guard services. New York City released its Final Adopted Rules for the program. Each nonpublic school with an enrollment of more than 300 will receive a letter directing them to “prequalify” online using the HHS Accelerator. If you need assistance using HHS Accelerator, you can register for training or contact the HHS Accelerator Helpdesk once you have logged into the system.
Do not delay. After completing the HHS Accelerator you will be contacted about signing a Memorandum of Understanding (MOU). A qualified nonpublic school will not be eligible to apply for reimbursement for any security services until an MOU has been signed by the school and registered with the Comptroller. Only expenses incurred after the signing of the MOU will be reimburseable.
If you are currently using a security guard provider they will have to register with the city in order to be an approved company. Click to the Frequently Asked Questions for more information.
To sign up for training, select a date below based on the status of your organization’s account with HHS Accelerator. Registration is required to attend trainings.
Getting Prequalified in HHS Accelerator (webinar)
This session is designed for organizations that are getting started in HHS Accelerator.
The session covers an overview of the system, how to upload and share documents, guidance on completing the HHS Accelerator Application to become prequalified.
Getting Prequalified in HHS Accelerator with On Site Support
AcceleratorAssist creates a space for providers to receive individual attention on the HHS Accelerator System and the process to get prequalified.
The session begins with an overview of the Prequalification Application and then providers are allotted a generous amount of time to work in the system with guidance from Accelerator staff. Registration is required.
Wednesday, July 27, 2016 9:30 AM – 12:00 PM
Wednesday, August 3, 206 9:30 AM – 12:00 PM
Wednesday, August 17, 2016 9:30 AM – 12:00 PM
Wednesday, August 24, 2016 9:30 AM – 12:00 PM
Competing for Funding Using HHS Accelerator System (webinar)
This session is primarily designed for pre-qualified organizations. Users whose organizations have applications which are nearly complete and are interested in specific upcoming procurements may also participate.
The session covers how to find Request for Proposals and submit proposals.
Managing Financials, Budgets, Invoices and Payments in HHS Accelerator (on site)
This training is only for organizations that use HHS Accelerator Financials.
The HHS Accelerator Financials module allows you to electronically submit budgets and invoices for review, start budget modifications, request advances and assignments, and track payments. This comprehensive session will provide you with an overview of each of the system’s capabilities. Please note this training is only for Providers who have been selected by their Agency to use HHS Accelerator Financials. Registration is required.
Submitting Budgets in HHS Accelerator (webinar)
This training is only for organizations that use HHS Accelerator Financials.
This shorter session is designed for organizations who will be submitting budgets in HHS Accelerator for fiscal year 2017. This session covers how to submit budgets, advances and budget modifications in HHS Accelerator.
Submitting Invoices in HHS Accelerator (webinar)
This training is only for organizations that use HHS Accelerator Financials.
This shorter session is designed for organizations with Approved budgets in HHS Accelerator that are ready to use HHS Accelerator Financials to invoice. This session covers how to submit invoices in HHS Accelerator and track payments.
- Prevailing wage. People have inquired how to determine the “prevailing wage” in the HHS Accelerator. Prevailing wages are set by the New York City Comptroller and can be found on p. 19 in this document. For those who want the 2016-2017 answer instantly:
SECURITY GUARD (UNARMED)
For the period: 7/1/2016 – 12/31/2016: $14.30 (hourly wages) + $5.04 (supplemental benefit rate per hour)
For the period: 1/1/2017 – 6/30/2017: $14.40 (hourly wages) + $5.22 (supplemental benefit rate per hour)
- Guidelines for hiring a security contractor. This ADL publication raises a number of important issues. Remember, security guard companies on the NYC approved list are required to submit information on their financial resources, technical qualifications,experience, record of performance and record of business integrity. They also must comply with NYS requirements such as licensing and background checks.
Click here to read JCRC-NY’s comments on the proposed rules.
Intro 65, the nonpublic school security guards bill authored by CM David Greenfield, passed by the New York City Council in December, 2015 and signed by Mayor de Blasio in January, will fund security guards in private and parochial schools with more than 300 registered students. New York City is moving ahead with implementation, with the hope of having the program in place by the start of school in September.
If you anticipate that your nonpublic school will have an enrollment exceeding 299 students we strongly urge you to follow this link to the HHS Accelerator and complete the submissions before the end of June. After completing the HHS Accelerator, schools will be eligible to apply to participate in the reimbursement program.
The New York City Department of Citywide Administrative Services (DCAS) drafted proposed rules and will hold a public hearing on June 27, 2016 at 3:00 PM in the Auditorium at 125 Worth Street, New York, New York 10013. You must register if you wish to submit comments on the proposed rules. You can view the proposed rules here. Several organizations, including the JCRC-NY, are reviewing the rules and will make comments. If you’ve read the FAQ’s and still have questions contact us here.
DCAS’ FAQ’s follow. Of course, the rules, which will be finalized after the hearings, will be definitive. Here are the FAQ’s (slightly edited for clarity):
Who is administering the program?
- The Department of Citywide Administrative Services (DCAS) was designated as the administering agency by Mayor de Blasio on March 10, 2016.
When does the program begin?
- Reimbursement will be available for the 2016-2017 school year, starting from the date that an MOU (i.e., a contract) is signed. At this time, we anticipate that the contractual agreement will take the form of a Memorandum of Understanding (MOU) and that it will require registration with the Comptroller.
Do I need to sign a contract with the City to receive reimbursement?
- Yes, each school must enter into a signed MOU (i.e., a contract) with DCAS before any reimbursements will be provided. Upon registration of each school’s MOU, qualified nonpublic schools will be able to submit reimbursement requests on a quarterly basis.
Who is eligible to participate?
- A qualified nonpublic school is a nonprofit elementary or secondary school in New York City, other than a public school, that provides instruction in accordance with the education law, has been assigned a Basic Educational Data System (BEDS) code by the New York State Department of Education, or similar successor identifier, and is serving students in any combination of grades from pre-kindergarten through twelfth grade.
Will the program reimburse schools for an unlimited number of security guards?
- No. The program will provide reimbursement to qualified nonpublic schools for the allowable costs 0f retaining certain security guards based on the number of students enrolled at such school.
- Approved schools that enroll between 300 and 499 students shall be reimbursed for the cost of one (1) security guard;
- approved schools that enroll between 500 and 999 students shall be reimbursed for the cost of two (2) security guards; and
- approved schools shall be reimbursed for the cost of an additional security guard for each additional 500 students enrolled in such school.
How does a school apply?
- If a nonpublic school wants to participate in the program during the 2016-17 school year, the school will be required to complete an application. The forthcoming application will be administered by DCAS through the HHS Accelerator system. In order to access the application, a nonpublic school must first be prequalified in HHS Accelerator.
What is HHS Accelerator?
- HHS Accelerator is the City’s online system for health and human service procurements and financial management, which was launched to simplify and speed the contract process for Client and Community based Services providers. HHS Accelerator will reduce paper-based submissions in the financial management of the reimbursement program.
Does being prequalified in HHS Accelerator ensure participation in the program?
- No. Prequalification only ensures that your school meets the standards set forth by HHS Accelerator to utilize their system for this program and also apply to other relevant procurements in HHS Accelerator that your school may be interested in pursuing. A school will still need to complete an application for reimbursement at a later date. Once the application is available, those schools that have been prequalified to use HHS Accelerator will receive an email notification.
When will an application be available?
- DCAS is working to finalize the application as well as rules that offer participants further guidance. Once completed, schools will be notified by DCAS and HHS Accelerator that an application is available for completion. In response to such applications, DCAS will inform schools if they meet the definition of “qualifying nonpublic school” and the number of guards for which they are eligible to receive reimbursements.
How often can a school submit for reimbursement?
- Schools will submit their requests for reimbursements on a quarterly basis. DCAS will provide additional information on the reimbursement schedule prior to the start of the program.
How does a school submit invoices?
- All payments will be processed using HHS Accelerator. DCAS will provide additional information on payment processing prior to the start of the program.
What activities are eligible for reimbursement?
- A qualified nonpublic school may be reimbursed for allowable costs of a security guard used to provide security services when the school is open for school-related instruction or school-related events. Reimbursements shall be given for security guards who provide security services and no other services.
- Forthcoming rules will be promulgated by DCAS that will provide additional guidance on allowable costs and what activities are eligible for reimbursement.
What qualifies as a student for purposes of determining how many security guards a school is eligible to claim reimbursement?
- A student is deemed to refer only to full time students meaning they attend school for six hours and twenty minutes a day. Students to whom the city separately provides assistances that includes funding for security are not included in the reimbursement determination. Schools will be required, upon application to the program, to provide the total number of students enrolled in the school. Schools must revise their application if the total enrollment changes as of the date the school provides this information to the New York State Education Department Basic Educational Data System (BEDS) Report of Nonpublic Schools.
Can a school use any security guard vendor?
- No. DCAS will establish a list of qualified vendors. In order to receive reimbursements, schools will only be able to utilize firms that are on the qualified provider list. Once a list is available, DCAS will notify schools of its availability via email or letter.
What salary is expected to be paid to security guards under this program?
- Security guard wages equal to the prevailing wage and supplements are allowable costs for qualified nonpublic schools under this program. “Prevailing wage and supplements” means the rate of wage and supplemental benefits per hour paid in the City of New York to unarmed security guards as determined by the Comptroller of the City of New York in accordance with section 234 of the labor law. For more information on prevailing wage, visit the New York City Comptroller’s website at: http://comptroller.nyc.gov/prevailing-wage/wage-schedules/.