Functional Behavior Assessment in Arizona: What Parents Need to Know

Your child is being suspended repeatedly, or the school is calling you to pick them up early because of behavior. You've heard the phrase "functional behavior assessment" but nobody at the school has initiated one — and you're not sure whether to push for it, what it actually involves, or what the school is supposed to do with the results. Here is the Arizona-specific picture.

What a Functional Behavior Assessment Actually Is

A Functional Behavior Assessment (FBA) is a structured process for identifying why a specific behavior is occurring — the function it serves for the child — so that an intervention can be designed that addresses the underlying cause rather than just suppressing the behavior.

Every behavior serves a function. The four most common in school settings are:

1. Escape — the behavior removes the child from a demand or an unpleasant situation
2. Attention — the behavior produces adult or peer attention
3. Access — the behavior results in obtaining a preferred item or activity
4. Sensory/automatic — the behavior produces internal stimulation regardless of the social environment

If a school responds to escape-maintained behavior with exclusion (suspension, removal to the hallway), they are accidentally reinforcing the behavior — giving the child exactly what the behavior was designed to produce. An FBA identifies the function so the Behavior Intervention Plan can provide an appropriate alternative.

When an FBA/BIP Response Is Required

Under IDEA and Arizona's implementing rules (A.A.C. R7-2-401), an FBA/BIP response is tied to particular discipline and behavior circumstances, not automatically to the 11th removal day:

1. When a disciplinary removal becomes a change of placement, the team must conduct a Manifestation Determination Review (MDR) within 10 school days of the decision to impose that removal.
2. When the conduct is found to be a manifestation, the PEA must conduct or review the FBA and develop or modify the BIP as applicable.

You can also request an FBA at any time as part of the IEP process — it doesn't have to be triggered by discipline. If your child's behavior is preventing them from accessing their education, an FBA may be appropriate and you can request one in writing. If the request is for an initial evaluation, the PEA's 15-school-day response rule applies; there is no universal 15-day deadline for every standalone FBA request.

Arizona's BCBA Licensure Crisis: What It Means for Your Child's School

This is a situation unique to Arizona that many parents don't know about. Arizona passed A.R.S. § 32-2091.08, which included an exemption allowing school-employed behavior analysts to operate without full BCBA licensure. That exemption was legally challenged and invalidated. School-based behavior analysts were required to apply for full state licensure by June 1, 2025; unlicensed practice is identified as a class 2 misdemeanor.

The impact: Arizona had significant numbers of school staff conducting FBAs and implementing behavioral supports who held lesser certifications. With the exemption gone, many districts face a shortage of qualified behavioral staff — particularly smaller districts and charter schools. In practice, this may mean:

• Longer waits to have an FBA conducted
• Schools relying on staff who are not fully qualified for complex behavioral cases
• IEP teams that are unable to staff a BCBA for an IEP meeting

If the FBA is part of an initial evaluation, the 60-calendar-day evaluation period runs from the PEA's receipt of informed written consent. Ask in writing who will be conducting the FBA and what their qualifications are.

What a Behavior Intervention Plan Should Address

When an FBA identifies a need for a behavior plan, the team should develop a Behavior Intervention Plan (BIP). A useful BIP is not just a list of consequences. It should address:

• Operational definition of the target behavior — precisely described so that any staff member reading it would identify the behavior consistently
• Identified function of the behavior — based on FBA data, not assumption
• Antecedent strategies — modifications to the environment or demands that reduce the conditions that trigger the behavior
• Teaching replacement behaviors — functionally equivalent behaviors that serve the same purpose as the problem behavior (if escape-maintained, teaching a break-request card, for example)
• Consequence strategies — how staff respond to both the problem behavior and the replacement behavior
• Reinforcement plan — how and when appropriate behavior is reinforced
• Data collection method — how progress toward BIP goals will be measured
• Crisis procedures if needed

A BIP that consists only of point sheets, loss of privileges, and behavior contracts may be inadequate — it contains consequence strategies without teaching replacement behaviors or addressing antecedents. Arizona parents can challenge an inadequate BIP at any IEP meeting.

BIP Template Standards

A BIP template must do more than list behaviors and consequences. The behavioral intervention plan template provided to parents in Arizona schools has no mandated statewide format — Arizona's S.B. 1463 requires the ADE statewide IEP template or a substantively identical digital platform for public schools and charters by July 1, 2026, but this does not currently mandate a BIP format. Districts use widely varying formats.

The standard Arizona parents should use: the BIP should address the relevant elements above, regardless of the template used. If your child's BIP is three sentences and a consequence grid, it may be inadequate.

What to Do If the School Is Refusing or Delaying

If your child is accumulating suspension days and the school has not initiated an FBA, put your request in writing immediately. If you are at day 9 of cumulative removals, write on that day — do not wait. If the removal becomes a change of placement, request the MDR and the applicable FBA/BIP review; your written request protects the record.

If the district conducts an FBA and the resulting BIP appears inadequate, you have the right to request an Independent Educational Evaluation — which can include an independent FBA by a qualified BCBA not employed by the district.

Raising Special Kids (RSK) offers training on Arizona's behavioral support requirements. The Arizona Center for Disability Law (ACDL) handles cases where districts are using exclusionary discipline illegally with students who have disabilities.

The Arizona IEP & 504 Blueprint includes a BIP adequacy checklist, a sample FBA request letter, and guidance on Arizona's discipline procedures under A.A.C. R7-2-401.

See more Arizona guides →