What is a Functional Behavior Assessment?

A functional behavioral assessment (FBA) is a process for identifying a specific behavior that interferes with a student’s learning and the reasons behind it, according to guidance the U.S. Department of Education issued in November 2024. The assessment describes the behavior in observable terms, looks at what happens before and after it, and forms a hypothesis about the purpose the behavior serves for the student. That understanding informs a plan, often called a behavior intervention plan (BIP), that teaches the student skills to meet the same need in a way that does not interfere with learning, as the same guidance describes.

When to do a Functional Behavior Assessment?

There is no single formula for deciding when to do a functional behavior assessment. Federal guidance says FBAs can and should be used for any student whose behavior interferes with learning, whether or not the student has a disability, and that they help with behaviors that are not safety-related, such as talking out, not following directions or name calling, as well as with aggressive behavior (U.S. Department of Education, 2024). An FBA often starts when parents, teachers or other school staff raise concerns about a pattern of behavior that keeps getting in the way of a student’s learning or the learning of classmates. It can be part of a student’s individualized education program (IEP), a school’s student assistance team process or a special education evaluation, as the sections below explain.

When IDEA requires an FBA

For students with disabilities, the Individuals with Disabilities Education Act (IDEA) requires an FBA in certain discipline situations:

• When the behavior is a manifestation of the disability. If the school, the parent and relevant members of the IEP team decide that conduct leading to a disciplinary change of placement was caused by, or had a direct and substantial relationship to, the student’s disability, or resulted from the school’s failure to implement the IEP, the IEP team must conduct an FBA (unless one was done before the behavior occurred) and implement a BIP, or review and modify an existing BIP (34 CFR 300.530).
• When a longer removal goes ahead. A student with a disability who is removed for more than 10 consecutive school days for conduct that is not a manifestation of the disability, or who is placed in an interim alternative educational setting for up to 45 school days for weapons, illegal drugs or serious bodily injury, must receive, as appropriate, an FBA and behavioral intervention services designed to keep the behavior from recurring (34 CFR 300.530).

Outside discipline, IDEA requires the IEP team to consider positive behavioral interventions and supports for any student with a disability whose behavior impedes their own learning or the learning of others, and an FBA is one way the team can understand those needs (U.S. Department of Education, 2024).

The Functional Behavior Assessment as Part of the Individualized Education Program (IEP)

IDEA Part B funds special education and related services for children with disabilities ages 3 to 21, and each eligible student’s services are set out in an individualized education program, or IEP (U.S. Department of Education, 2024). IDEA also requires that children with disabilities be educated with children who are nondisabled to the maximum extent appropriate (34 CFR 300.114). For a fuller overview, see how special education and IEPs work under IDEA. Section 504 of the Rehabilitation Act is a separate civil rights law. The Department of Education’s Section 504 regulation prohibits discrimination on the basis of disability in any program or activity that receives federal financial assistance (34 CFR 104.4).

Within the IEP process, an FBA can help the team identify behavioral interventions and supports to include in the student’s IEP. Data from the FBA and the resulting BIP can inform the student’s present levels of functional performance, measurable annual goals, services, supplementary aids and accommodations, and a BIP that is part of an IEP must be accessible to every teacher and service provider responsible for carrying it out (U.S. Department of Education, 2024).

The Functional Behavior Assessment as Part of the SAT Process

Many schools use a student assistance team (SAT), sometimes called a student support team, to respond to concerns about a student’s learning or behavior. How these teams are set up and run varies by state and district. New Mexico’s state education rules, for example, define an SAT as “a school-based group of people whose purpose is to provide additional educational support to students experiencing difficulties preventing them from benefitting from general education” (6.29.1.7 NMAC).

Federal guidance notes that some schools have student assistance or support teams that can help develop and monitor a student’s behavior plan. The people who create and carry out such a plan may include the student’s teachers, specialized instructional support personnel, school leaders, school counselors, psychologists or other mental health personnel, parents and, when appropriate, the student. An FBA can give the team a clearer picture of why a behavior is happening before it plans those supports (U.S. Department of Education, 2024).

An FBA does not take the place of a special education evaluation. A school that suspects a student has a disability cannot use an FBA to delay or deny an evaluation under IDEA or Section 504 (U.S. Department of Education, 2024).

The Functional Behavior Assessment as Part of a Special Education Evaluation

An FBA can also be one of the assessment tools a school uses in an initial evaluation or reevaluation to decide whether a student has a disability under IDEA and what services the student needs. IDEA requires evaluations to use a variety of assessment tools and strategies, and no single measure can be the only basis for deciding eligibility or the student’s program, so an FBA adds information alongside observations, records and input from parents and educators (U.S. Department of Education, 2024). When an FBA is part of an initial evaluation or reevaluation, the school must obtain parental consent before conducting it, and parents who disagree with the school’s evaluation have the right to request an independent educational evaluation at public expense (U.S. Department of Education, 2024).

What Happens During the FBA?

According to federal guidance, an FBA generally includes four parts: a clear, objective description of the behavior; data collection; a review of the data to identify the behavior’s function; and a focus on the skills the student needs to develop. Teams usually work through the five steps described below to:

• Identify the target behavior
• Gather objective information and observations
• Develop intervention plans to change the target behavior

Who Conducts an FBA?

Federal guidance says an FBA works best when professionals with the necessary skills, training and knowledge collaborate with parents and, when appropriate, the student. Examples include general and special education teachers, early childhood providers, school psychologists and school counselors, speech-language pathologists, occupational and physical therapists, behavioral specialists such as behavior analysts, administrators and community-based professionals. Which professionals take part depends on the student’s needs, how well they know the student and the intensity and complexity of the behavior (U.S. Department of Education, 2024).

Indirect vs. Direct FBA

Five Steps of the Assessment Process

Identifying the Suspect Behavior

The SAT or IEP team reviews the available information to decide which behavior most interferes with the student’s learning. That behavior becomes the target behavior. Federal guidance calls for describing it in clear, specific, measurable, observable and objective terms (U.S. Department of Education, 2024), such as “talks out during independent writing time” rather than “is disruptive.”

Gather Information and Facts

The data should be observable and, as far as possible, measurable. The team studies the behavior in the setting where it happens, connects it to the environment and looks for its purpose, using the antecedent-behavior-consequence (ABC) approach common in applied behavior analysis. Observers chart how often the behavior occurs and how long it lasts, using samples taken through the day or continuous records across one or more days. These records help pinpoint the times and situations in which the behavior occurs and provide a baseline for later comparison. Examples of the information a team gathers include:

• Locations where the behavior occurred and the people involved
• Whether those involved were peers or adults
• The events that happened just before the behavior, as possible predictors or triggers
• The events immediately after the behavior and its consequences
• What, if anything, was attempted to prevent or interrupt the behavior
• Whether and how the behavior ended
• Possible reasons for the behavior, such as getting attention, avoiding a task or opposing an action
• The classroom or other environment, its structure and the level of adult attention at the time of the behavior
• The instruction and the academic and behavioral expectations at the time
• Recent changes in the student’s life in or out of school, including community or medical issues, and whether public or private agencies are involved
• Existing records such as attendance, academic performance and prior behavioral incidents (U.S. Department of Education, 2024)

Supporting the Hypothesis

The team then makes a reasoned hypothesis about the link between the behavior and its purpose. Federal guidance says the function of a behavior is typically categorized as an effort either to obtain something or to escape or avoid something (U.S. Department of Education, 2024):

The hypothesis guides the first intervention plan, and the results test whether it was accurate. Good practice draws on the student’s strengths, needs and history of responses to earlier interventions. For example, the guidance describes a student who talks during silent writing time to avoid a task the student finds difficult; a plan built on that function might break writing assignments into smaller segments and teach strategies for approaching difficult work (U.S. Department of Education, 2024).

Developing Interventions and Strategies

The written plan, often a behavior intervention plan (BIP), identifies the changes the team wants to see in the student’s behavior. According to federal guidance, a plan generally describes the behavior and its function, the environmental factors that contribute to it, strategies to prevent it, the skills the student will be taught to meet the same need, how the student will be recognized for using those skills, who is responsible for carrying out the plan and how progress will be measured.

Evaluation

The data collected at the start provide a baseline, and repeating the same data collection gives an early measure of progress. Evaluation closes the loop between the plan and the next step: favorable data support continuing the approach, while data showing little or no improvement call for reconsidering the hypothesis or the strategies.

Frequently Asked Questions About FBAs

Can a parent request a functional behavior assessment?

Parents can ask the school or the student’s IEP team for an FBA whenever they believe behavior is getting in the way of learning. Parents are members of the IEP team, and federal guidance describes an IEP team, including the student’s parents, deciding together to conduct an FBA (U.S. Department of Education, 2024).

Do parents have to consent to an FBA?

It depends on how the FBA is used. Under IDEA, parental consent is required when an FBA is part of an initial evaluation or reevaluation, and before an FBA conducted under the discipline provisions described above. Consent is not required when an FBA is done as a screening for instructional purposes or as a review of existing data, such as classroom observations, though federal guidance stresses involving parents throughout (U.S. Department of Education, 2024).

What is the difference between an FBA and a BIP?

An FBA is the assessment that explains why a behavior happens. A behavior intervention plan (BIP) is the plan built from those findings, setting out the strategies, skills and supports that address the behavior’s function (U.S. Department of Education, 2024).

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