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 Arizona Law Requires an FBA

Under IDEA and Arizona's implementing rules (A.A.C. R7-2-401), an FBA is specifically required in two situations:

1. When a student with a disability is removed from their educational placement for more than 10 school days in a school year (cumulative), and behavioral issues were a contributing factor. At the 11th removal day, the district must conduct an FBA and develop a Behavior Intervention Plan (BIP) if one doesn't already exist.

2. At a Manifestation Determination Review (MDR) where the behavior is determined to be a manifestation of the disability. If the team finds the behavior was caused by the disability, the district must conduct or review the FBA and modify the BIP.

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 is appropriate and you have the right to request one. Submit the request in writing; the district has 15 school days to respond under A.A.C. R7-2-401.

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. As of June 1, 2025, all behavior analysts working in Arizona schools must hold full BCBA licensure.

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 you request an FBA and the district takes longer than the standard evaluation timeline (60 calendar days after consent), ask in writing who will be conducting the FBA and what their qualifications are. You are entitled to this information.

What a Behavior Intervention Plan Must Contain

After an FBA, the team must develop a Behavior Intervention Plan (BIP). A legally sufficient BIP is not a list of consequences. It must include:

• 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 is not a compliant BIP — 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 ADE to develop a statewide IEP template by July 1, 2026, but this does not currently mandate a BIP format. Districts use widely varying formats.

The standard Arizona parents should hold their district to: the BIP must contain every element listed above, regardless of the template used. If your child's BIP is three sentences and a consequence grid, it is not adequate.

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. The district's obligation to conduct the FBA is triggered at day 11, but 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.

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