Special Education Law Blog: Guidelines and Observations Regarding Functional Behavioral Assessment ("FBA")

A Functional Behavioral Assessment ("FBA") is one of the most critical parts of an IEP for children who have behaviors that impede their education. As a preliminary matter, this planning process involves a good understanding of what is meant by the term "behavior". This term does not exclusively or even primarily mean acting out or violent conduct. A behavior is anything that the child does that interferes with learning, from being inattentive to falling asleep or having full-blown tantrums.

The process begins with the FBA, which looks at the communicative intent of the behavior, or the functional aspect of the behavior. The underlying assumption is that all people behave in a certain way to communicate wants, needs, desires or some other meaning (e.g. I am overwhelmed, I am upset etc.) . FBAs take a holistic analysis of the child's environment, typically in school. If well done, the FBA process will include the parents, it will be based on good data over a period of days and weeks, and it will be revisited over time to evaluate the validity of the hypothesis that grows out of the FBA.

There can be many pitfalls in the FBA process. Too often, FBAs are done incorrectly, they are done too late, and they simply do not improve the outcomes for either the staff or student. Below, I have recorded some of my personal observations about FBAs and some recommendations for improving this important part of the IEP process.

Behaviors are one of the primary causes of due process and dissension between parents and schools.
A disproportionate amount of resources are spent “managing” behaviors that are not well understood.
Functional behavioral assessments (“FBA”) are based upon data collection, and too often, the data is flawed and parents are left out of the process.
FBA is meant to be an objective process that supports learning, not simply a vehicle to justify moving a child to a more restrictive setting.
FBA is meant to be a dynamic process that changes over time as the circumstances change, the behaviors change, and the ecology changes. An FBA that was developed in year one for creating an FBA is not very useful or even valid for subsequent years.
Though the forms suggested by the Illinois State Board of Education (“ISBE”) do not contain the word hypothesis, hypothesis development is the end product of an FBA. The hypothesis is a global explanation of the behavior based upon data that leads to positively and proactively addressing the behavior.
ISBE forms for FBAs are a staring point, not an ending point. The forms are small and cramped and do not serve very well to suggest the degree of complexity needed to develop a good FBA.
Multiple behaviors should not be analyzed on the same data collections sheets. It is highly unlikely that different behaviors serve the same or even similar functions. Cross analyzing behaviors (typically as a function of the forms used) leads to bad analysis, confusion and an invalid FBA.
Too many FBAs conclude that the function of the behavior is “internal causes” or that all behaviors are for “task avoidance.” Such conclusions are a sure sign that the FBA should be thrown out and a new, more in-depth process begun. "Internal causes" is a fancy way of saying the staff doing the FBA has no idea what is driving the behavior. A fundamental assumption of the FBA process and the psychology that underlies it is that people behave in a way that makes sense to them, serves a purpose, has a communicative component, and is subject to scientific analysis. Puberty, hormones, and other imponderables may play a role, but given enough good comprehensive data, the function of the behavior should become known.
Task avoidance is often used a catch-all for behaviors. The irony of this explanation is that staff is often avoiding the task of doing a thorough FBA. A child who has difficulty cutting, pasting and gluing, and who has a tantrum every time he or she is faced with a fine motor task is in one sense avoiding something. However, the real “functional communication” is frustration that the activity has not been appropriately adapted. Staff need to be open and honest about the fact that the behavior is being driven as much by defects in the design of the IEP than any basic issues with the child.
Hash marks are not substitutes for behavioral data. FBAs are about putting behaviors in a proper context -- duration, frequency, intensity, topography (time of day/location/hydration/hunger) -- to isolate the antecedent of the behavior. Behavior analysis is all about manipulating the environment and reshaping the antecedents. If we cannot validly identify the antecedents, then we cannot produce a useful FBA.
Avoid moral judgment! The reality is that in many situations when staff is undertaking an FBA, significant behaviors have occurred, too often of a violent nature. Thus, rationale analysis often is colored with emotion, anger, fear and hostility. First, FBAs are best begun when things are not out of hand and violence has not erupted. Behaviors that are understood early are more easily analyzed and addressed. Second, at the point when staff wants the child’s placement changed, it is almost impossible to be objective, which is a necessary part of the FBA process.
Staff training is crucial. Too often, paraprofessionals who are working closely with the child do not have an overall understanding of what an FBA is about. For instance, an antecedent is not a cause of the behavior; it is an event that occurs just prior to the behavior. Though data collection forms are not necessarily complicated, they need to be explained in terms of what should be collected and what is relevant to the process. Parents do not often understand what FBAs are about, and just like with paraprofessionals, parents needs training to provide good quality data.
Too often, FBAs are perceived as being negative and something to be avoided at all costs. Staff might tell parents, “you do not want an FBA, because then, your child will be considered a behavior problem.” In this instance, "behavior problem" is always negative and implies violent, acting-out behaviors. The reality is that the law is much broader. Any behavior that is interfering with the child’s education can be the subject of an FBA. The process is meant to be proactive and positive in nature. Parents often do not understand that an FBA is and should be a supportive diagnostic that can avoid more painful choices down the road.
Avoid the pitfall of imposing FBA on the parent. First, parents must be on board with the process to the fullest extent possible. They have valuable data to add to the process. Second, if the FBA is perceived negatively, everything that flows from it will be regarded with suspicion and distrust. If relations have broken down, look for a neutral party, an “honest broker” who is objective, to lead the FBA process in data gathering.
Inappropriate behaviors are not always unreasonable. A grade-school child who has no reliable means of communication is going to act out in one way or another, whether outward or inward; that is a given. Communication in its many forms is basic to the human condition. The first line of analysis for any FBA is what the barriers are to communication and how we can ultimately remediate these barriers.
Most behaviors are not extreme or intractable. FBAs can and do result in positive breakthroughs for children. They should be approached with that frame of mind and presented to parents in such optimistic terms.
FBAs do not often require a lot of time and should not be regarded as a last resort. Alternatively, even if the FBA is time consuming, it is time well spent. It can have enormous positive consequences for children and staff. Failing to undertake a timely and valid FBA can result in a more restrictive placement, loss of staff morale, due process and long hearings, and even injury to students or staff.
FBAs are individual in nature. Avoid the temptation to assume that the function of the behavior is the same for all children with autism (for instance). Even the same child who exhibits the same behavior from year to year may have a different function purpose and communication over time and across different settings.
Behaviors must be prioritized. Which behaviors are interfering most with the child’s education? Which behavior is idiosyncratic, and which is anti-social and will likely result in more dire consequences if not understood and addressed? Which behavior, while not normative, can be re-framed and made to have a functional purpose?