Things to Know About Functional Behavioral Assessments

Written by Michelle Reed-Harris

With over 15 years in special education advocacy, I draw from personal experience and a scientific background to empower families. Diagnosed with learning disabilities in my 40s, I understand firsthand the challenges of unmet needs. As a parent of children with diverse needs, including surviving quadruplets with autism, I’m passionate about guiding families in effective advocacy, interpreting educational data, and promoting inclusive support.

Disability Awareness and Acceptance | IEP & 504 Plan Guidance | Special Education Laws & Rights | Special Needs Resources

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November 28, 2024

Functional Behavioral Assessments (FBAs)

Functional Behavioral Assessments are essential tools for understanding and addressing behaviors that interfere with learning. Federal guidance emphasizes their use not only for students with disabilities but also for any student whose behavior affects their educational experience. Here’s what parents need to know about FBAs and how to advocate effectively for their children. 

1. FBAs Are for Everyone—Not Just Students with Disabilities

Functional Behavioral Assessments are no longer solely for students receiving services under the Individuals with Disabilities Education Act (IDEA). They are encouraged for any student whose behavior disrupts their education or that of their peers. FBAs help identify the function of a behavior—whether the student is seeking something, such as attention, or avoiding something, like a challenging task.

The 2024 federal guidance from the Office of Special Education Programs (OSEP) stresses the importance of FBAs for all students, seeing them as proactive ways to help students get into school and lessen the need for practices that keep them out. While 34 CFR § 300.530(f) requires that an FBA be conducted for students with disabilities when a disciplinary removal constitutes a change in placement, this guidance broadens their application to address behaviors that interfere with learning for any student. FBAs also align with frameworks like the Elementary and Secondary Education Act’s (ESEA), Multi-Tiered Systems of Support (MTSS), and Response to Intervention (RTI). These frameworks promote proactive, school-wide strategies to create inclusive learning environments through increasing tiers of Positive Behavioral Interventions and Supports (PBIS).

Supporting Resources for Parents

What This Means for Parents
Advocate for a functional behavioral assessment if your child’s behavior interferes with their own learning or the learning of others, regardless of whether they have a diagnosed disability. A functional behavioral assessment can provide valuable insights into the support your child needs and help prevent behaviors from escalating. If your child requires an functional behavioral assessment, it may also indicate a need for an evaluation for an IEP or a Section 504 Plan. If you feel your child needs an FBA, contact an advocate with PASEN. We can help determine if your child should have an FBA and, if needed, how to get the school to supply it. 

functional behavioral assessments should not be a punishment

2. Functional Behavioral Assessments Should Be Proactive, Not Reactive

Functional Behavioral Assessments should not be limited to addressing severe safety-related behaviors or incidents that have already resulted in disciplinary actions. Federal guidance emphasizes the importance of using FBAs for less severe but disruptive behaviors, such as avoiding tasks, refusing to follow directions, or withdrawing from peers. By identifying these issues early, schools can implement supports that prevent behaviors from escalating and interfering with a student’s education.

Under 34 CFR § 300.324(a)(2)(i), IEP teams are legally required to consider the use of positive behavioral interventions and supports (PBIS) for students whose behaviors impede their own learning or the learning of others. This regulation aligns with the guidance from the Office of Special Education Programs (OSEP), which encourages schools to use FBAs as proactive tools for early intervention. FBAs are not just quick fixes; they are part of a bigger plan that includes Multi-Tiered Systems of Support (MTSS) and PBIS to make schools more supportive places that can predict and deal with behavior problems in a good way.

Supporting Resources for Parents

  • The 2022 OSEP Guidance on Discipline and Behavior clearly states that schools must not wait for major disciplinary incidents to act. Instead, schools should use data-driven tools like FBAs to understand and address the causes of disruptive behavior before they escalate.
  • The 2024 OSEP Guidance on FBAs reinforces this point, explaining how FBAs are valuable for all students, including those without IEPs or Section 504 Plans, to ensure that their behaviors are addressed constructively.

What This Means for Parents
Do not wait for serious behavioral or disciplinary issues to arise before taking action. If your child exhibits behaviors that disrupt learning—whether through avoidance, defiance, or withdrawal—submit a written request for an FBA as soon as possible. Addressing behaviors proactively can help identify their underlying causes and lead to effective, tailored support.

Always communicate with the school in writing to build a clear record of your requests and the school’s responses. Include specific details about your child’s behaviors and reference federal regulations such as 34 CFR § 300.324(a)(2), which requires IEP teams to consider behavioral interventions for students whose behaviors impede learning. Maintaining this paper trail ensures your concerns are documented and helps protect your child’s right to appropriate support. For additional ideas on how to document issues effectively, check out our blog post, IEP Documentation Strategies. 

parental concent is required in functional behavioral assessments

3. Importance of Parental Consent and Involvement Under IDEA

Parental consent is legally required for FBAs conducted as part of an initial evaluation or reevaluation under the Individuals with Disabilities Education Act (IDEA). According to 34 CFR § 300.300, schools must obtain informed written consent before performing these assessments. Your involvement ensures that the FBA reflects your child’s unique needs by incorporating insights about their behavioral patterns, triggers, and environment.

You have the right to request an Independent Educational Evaluation (IEE) at public expense under 34 CFR § 300.502. If you disagree with the results of an FBA included in a larger evaluation, such as an initial or reevaluation under IDEA, consider requesting IEEs for all areas where you believe the evaluation was inadequate.

Parents are entitled to only one IEE per evaluation conducted by the school, so it’s critical to address all areas of disagreement in your request. This is a good time to seek the help of a PASEN advocate, who can guide you through the process and ensure your request is well-prepared.

If the school failed to assess an area of suspected disability in the evaluation, you can first ask the school to conduct that assessment. If the school refuses, you have the right to request an IEE at public expense for the unassessed area. Schools are required under 34 CFR § 300.304(c) to evaluate all areas related to a suspected disability.

When requesting an IEE, submit your request in writing and state your disagreement with the evaluation. While you are not required to specify concerns, sharing details can improve outcomes. An advocate can offer advice on what to include to strengthen your request. Once the IEE request is submitted, the school must either approve it or file for due process to defend its evaluation.

Supporting Resources for Parents

What This Means for Parents
You have a legal right to be actively involved in every step of the FBA process. To tailor the assessment to your child’s needs, provide detailed input about their behaviors, triggers, and strengths. Ask questions about how the FBA will be conducted, who will perform it, and how the findings will be used to support your child. 

If you disagree with the school’s conclusions or feel the FBA is incomplete, you can request an IEE to ensure your child’s needs are fully understood. For guidance on how to navigate the FBA process and advocate effectively, connect with experienced advocates at PASEN.

Functional Behavioral Assessments are used to avoid exclusionary punishments

4. Functional Behavioral Assessments Are a Key Tool for Addressing Exclusionary Discipline

Exclusionary discipline—such as suspensions, expulsions, and informal removals—disproportionately affects students of color and those with disabilities. Data from the U.S. Department of Education’s Office for Civil Rights shows these students are disciplined more frequently than their peers for similar behaviors.

Implicit bias often contributes to these disparities, as schools may misinterpret behaviors related to a child’s disability without considering their background or experiences. FBAs help reduce these biases by focusing on clear, measurable data rather than subjective opinions. By using culturally and linguistically responsive practices, schools can ensure fairness and equity while creating tailored interventions that meet students’ needs and decrease reliance on punitive measures.

Functional behavioral assessments offer a proactive solution by identifying the root causes of behaviors. Instead of relying on punitive measures, FBAs focus on evidence-based strategies that address the underlying issues and reduce the likelihood of future incidents.

Under 34 CFR § 300.530(b), schools must provide educational services for students with disabilities during disciplinary removals that constitute a change in placement. This protection also applies to informal removals, such as shortened school days, early pickups, or repeated administrative exclusions.

If informal removals happen repeatedly or extend beyond ten (10) days in a school year, they may violate a student’s right to a Free Appropriate Public Education (FAPE). Schools often fail to document informal removals like shortened school days or early pickups, making it harder to hold them accountable. Functional behavioral assessments are essential for addressing the root causes of these behaviors and creating Behavior Intervention Plans (BIPs) to prevent further exclusions.

A well-developed BIP provides targeted interventions to support the student while reducing reliance on both formal and informal exclusions. These plans help ensure students remain in school and receive the support they need to succeed.

Supporting Resources for Parents

What This Means for Parents
If your child faces frequent disciplinary actions, including informal removals, suspensions, or expulsions, it’s crucial to request an FBA. This assessment shifts the focus from punishment to proactive supports that address the underlying reasons for their behavior. An FBA can help develop a BIP that includes specific strategies and accommodations to support your child, whether in a traditional classroom or an alternative educational setting like online school. Ensuring these plans are in place is essential for your child’s continued educational progress and well-being.

5. Functional Behavioral Assessments Must Be Comprehensive and Evidence-Based

Effective Functional Behavioral Assessments require a thorough and detailed approach to understanding student behavior. Schools must collect data using multiple methods, including direct observations, interviews with teachers and parents, and a review of the student’s school records.

An FBA should analyze the environment, triggers, and outcomes of the behavior to determine its function. The function may involve the student trying to gain something, such as assistance or attention, or avoid something, like a challenging task or overwhelming situation. This analysis ensures the resulting Behavior Intervention Plan (BIP) is tailored to the student’s specific needs and addresses the root causes of the behavior.

Under 34 CFR § 300.304(c), IDEA mandates that evaluations, including FBAs, must be “sufficiently comprehensive” to identify all the educational and related services a child requires. This means the FBA must address all factors contributing to the behavior, including environmental, social, and academic influences. The results of the FBA should lead to a Behavior Intervention Plan (BIP) with specific, evidence-based interventions that are actionable and measurable. A strong BIP will also teach replacement behaviors to meet the same function in a more appropriate way.

Supporting Resources for Parents

What This Means for Parents
Ensure the functional behavioral assessment conducted for your child is thorough, based on observable data, and tailored to their unique needs. Request clear documentation of findings, including detailed explanations of the behavior’s function and its triggers. If the resulting Behavior Intervention Plan (BIP) is vague or generic, advocate for practical, measurable strategies that address your child’s specific challenges and include a plan to teach replacement skills.

FBAs can inform IEPs and 504a

6. Functional Behavioral Assessments Can Inform IEPs and 504 Plans

FBAs help identify the underlying causes of challenging behaviors and guide the development of supports within Individualized Education Programs (IEPs) and Section 504 Plans. Federal regulations under 34 CFR § 300.304 make it clear that schools cannot use a Functional Behavioral Assessment as a reason to delay or deny a comprehensive evaluation for special education eligibility. 

While an FBA does not create these plans, its findings equip the IEP or 504 team with the information needed to craft tailored goals, accommodations, and services that effectively address behavioral challenges. 

Federal regulations under 34 CFR § 300.324(a)(2) require IEP teams to consider the use of positive behavioral interventions and supports (PBIS) for students whose behavior interferes with learning. An FBA plays a critical role in identifying these supports, ensuring they are rooted in evidence-based strategies. 

The Behavior Intervention Plan (BIP) should be incorporated into the IEP to ensure consistency across all environments, including general education classrooms, special education settings, and non-academic areas. A well-developed BIP outlines specific interventions, replacement behaviors, and the responsibilities of all staff members to implement the plan effectively.

Supporting Resources for Parents

  • The OSEP 2024 Guidance on FBAs explains how FBA findings should inform IEPs and Section 504 Plans to address behavioral needs consistently.
  • IDEA Regulation, 34 CFR § 300.324(a)(2), outline the legal requirement for IEP teams to consider behavioral supports and interventions for students whose behaviors impede their learning.
  • The IDEA Procedural Safeguards Notice provides information on parents’ rights to request that FBA findings be included in their child’s IEP or 504 Plan.
  • The Center on PBIS offers resources to help parents understand how FBA data can be used to develop effective behavioral goals and supports.

What This Means for Parents
During IEP or 504 Plan meetings, ask how the findings from your child’s FBA will inform their plan. Ensure the behavioral goals and supports are clear, specific, and measurable. Advocate for the BIP to become part of the IEP or 504 Plan so that it is implemented consistently by all staff working with your child. 

Federal funding is available

7. Federal Resources and Funding Are Available

Federal programs allocate significant resources to help schools conduct high-quality FBAs and implement effective BIPs. Under IDEA, schools use funding to meet the needs of students with disabilities, including conducting comprehensive evaluations like FBAs and training staff in evidence-based behavioral strategies. The Elementary and Secondary Education Act (ESEA), through programs like Title IV, Part A, also provides funding to improve school climate, promote mental health, and support behavioral interventions such as FBAs and BIPs. Additionally, the Bipartisan Safer Communities Act expands funding to strengthen mental health supports and improve school safety, making FBAs and BIPs essential tools in creating positive learning environments.

These funding initiatives enable schools to hire qualified professionals, deliver professional development, and implement interventions that reduce reliance on exclusionary discipline. By using these resources strategically, schools can address students’ behavioral needs proactively and equitably, leading to better academic and social outcomes. Federal guidance directs schools to maintain transparency in fund usage and encourages collaboration with families to ensure effective allocation of resources.

Supporting Resources for Parents

  • The OSEP 2024 Guidance on FBAs explains how IDEA funds can be used to support FBAs, BIPs, and related professional development for educators and specialists.
  • The Bipartisan Safer Communities Act provides funding for mental health programs and behavioral interventions to enhance school safety and address student needs.
  • The ESEA Title I, II, and IV programs allocate resources for improving schoolwide support systems, including behavioral interventions and training for staff.
  • The U.S. Department of Education’s Budget Summary details how federal funding is allocated to support behavioral assessments and other critical programs.

What This Means for Parents
Ask your school or district how they are using federal funds, including IDEA and other resources, to support behavioral assessments and interventions. Advocate for these funds to be used to hire trained professionals, conduct high-quality FBAs, and implement evidence-based supports like BIPs. Understanding how schools allocate these resources can help you ensure your child receives the best possible support.

Conclusion

Functional Behavioral Assessments (FBAs) are invaluable tools for addressing behaviors that interfere with learning and ensuring students receive the supports they need to succeed. As this guide demonstrates, FBAs are not limited to students with disabilities but are a proactive, data-driven approach to understanding and improving behaviors for all students. They provide critical insights that inform interventions, guide the development of IEPs and 504 Plans, and reduce reliance on exclusionary discipline practices.

Parents play a vital role in the Functional Behavioral Assessment process. Whether by providing input, understanding their rights under IDEA, or advocating for evidence-based interventions, parents are key to ensuring FBAs are conducted fairly and effectively. By leveraging federal laws, guidance, and resources, you can advocate for high-quality FBAs and ensure your child’s needs are met within a larger system of support, such as MTSS or PBIS.

If you need assistance navigating the FBA process, understanding how it informs your child’s education plan, or ensuring timely evaluations, PASEN.org is here to help. Our experienced advocates can guide you through every step, ensuring your child receives the supports and services they need to thrive both academically and socially. Together, we can work toward creating supportive learning environments that foster equity, inclusion, and success for all students.

FAQs About Functional Behavioral Assessments

Q1. What is a functional behavioral assessment, and why is it important?
A1: An FBA, or Functional Behavioral Assessment, is a process used to identify the underlying causes of behaviors that interfere with learning. It helps schools develop strategies to address challenging behaviors proactively, ensuring students receive the support they need to succeed academically and socially. FBAs are crucial for creating effective Behavior Intervention Plans (BIPs) and preventing exclusionary discipline practices.

Q2. Can I request an FBA for my child even if they don’t have an IEP or 504 Plan?
A2: Yes, FBAs are not limited to students with disabilities or those with IEPs or 504 Plans. Federal guidance encourages the use of FBAs for any student whose behavior disrupts learning. If your child’s behavior is affecting their educational experience, you can submit a written request for an FBA to the school.

Q3. Do schools need my consent to conduct an FBA?
A3: Yes, under the Individuals with Disabilities Education Act (IDEA), schools must obtain written parental consent before conducting an FBA as part of an initial evaluation or reevaluation. Your involvement ensures the FBA is tailored to your child’s unique needs, incorporating your insights about their behavioral patterns, triggers, and strengths.

Q4. How does a functional behavioral assessment help create a Behavior Intervention Plan (BIP)?
A4: The data gathered from an FBA identifies the function of your child’s behavior—what they are seeking or avoiding. This information guides the development of a BIP, which outlines specific strategies, interventions, and replacement behaviors. A well-crafted BIP ensures consistency across all settings, helping your child succeed academically and socially.

Q5. How can I ensure the FBA process is effective for my child?
A5: To ensure an effective FBA, provide detailed input about your child’s behaviors, triggers, and environment. Advocate for the assessment to include multiple data sources, such as observations and interviews with teachers and caregivers. If you feel the FBA is incomplete or inadequate, you can request an Independent Educational Evaluation (IEE) at public expense to ensure your child’s needs are fully understood. Always communicate with the school in writing to document your concerns and requests.

Q6. Can a functional behavioral assessment delay or replace a comprehensive evaluation for special education eligibility?
A6: No, schools cannot use an FBA to delay or deny a comprehensive evaluation for special education eligibility. Federal regulations under 34 CFR § 300.304 explicitly require that all areas of suspected disability be evaluated, and an FBA should only supplement—not replace—a full evaluation. If your child shows signs of needing additional supports, advocate for a comprehensive evaluation alongside the FBA.

Q7. How does federal funding support the use of FBAs in schools?
A7: Federal programs like IDEA and the Elementary and Secondary Education Act (ESEA) provide funding to schools for behavioral interventions, including functional behavioral assessments and BIPs. Additionally, the Bipartisan Safer Communities Act offers resources to enhance mental health supports and improve school climate, making FBAs a critical component of proactive discipline strategies. Parents can ask their school or district how these funds are being used to support behavioral assessments and ensure transparency in resource allocation.

 

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