Behavior Intervention Plan in Colorado: What a Compliant BIP Must Include

Your child's school has proposed a Behavior Intervention Plan, or maybe you've been told they need one. Before you sign off on the document they've drafted, understand what a legally and clinically adequate BIP actually looks like in Colorado — because a BIP that is nothing more than a list of consequences is not an intervention. It is a punishment menu dressed up in special education paperwork.

The Legal Foundation for a BIP in Colorado

Under federal IDEA, when a student's behavior impedes their own learning or the learning of others, the IEP team must consider positive behavioral interventions and supports. This is not optional when behavior is a documented barrier. For students who have had a Manifestation Determination Review (MDR) and whose behavior was found to be a manifestation of their disability, the district must conduct an FBA and develop or review a BIP.

Colorado's ECEA doesn't specify a separate BIP statute beyond federal requirements, but CDE's implementation guidance and compliance reviews make clear that a BIP must be grounded in a Functional Behavior Assessment (FBA) and must include proactive, function-based strategies — not just reactive consequences.

A BIP that lacks FBA data, includes only disciplinary responses, or does not teach a replacement behavior is not a compliant BIP under the positive behavioral interventions and supports requirement.

What a Colorado BIP Must Include

A defensible BIP in Colorado contains:

1. Operational definition of the target behavior. The behavior must be defined in observable, measurable terms specific enough that any staff member in the building can recognize it consistently. "Aggression" is not a definition. "Striking a peer or staff member with an open or closed hand on the body" is. Without an operational definition, data cannot be reliably collected and progress cannot be monitored.

2. Baseline data. How often does the target behavior currently occur? The BIP should include frequency, duration, or intensity data collected before the intervention began, so that the effectiveness of the plan can actually be measured.

3. The identified function of the behavior. Based on the FBA, what is the behavior accomplishing for the student? Common functions include:

• Escaping or avoiding a demand, task, or person
• Accessing attention (adult or peer)
• Accessing a preferred item or activity
• Self-regulation (sensory or physiological)

A BIP that doesn't identify the function is intervention by guessing. If the behavior is escape-motivated and the BIP responds to every incident with removal from the classroom, the BIP is reinforcing the behavior.

4. Antecedent strategies. What will be changed in the environment, routine, or instruction to reduce the likelihood that the triggering conditions will occur? Antecedent strategies might include:

• Modified task demands or shorter work periods
• Priming or warning before transitions
• Choices embedded in activities
• Sensory tools available proactively
• Adjusted seating or environmental modifications
• Check-in with a preferred adult at the start of the school day

5. Teaching a replacement behavior. The BIP must explicitly identify a functionally equivalent behavior that serves the same purpose as the target behavior but is appropriate. If the behavior is escape-motivated, the replacement behavior might be requesting a break using a break card or an AAC device. The BIP must specify how the replacement behavior will be taught and by whom.

6. Consequence strategies for both the target and replacement behavior. What will staff do when the target behavior occurs? What will they do when the student uses the replacement behavior? Consequence strategies should be minimal in emphasis — the goal is to interrupt and redirect, not to punish.

7. Crisis procedures if relevant. For students with behaviors that may escalate to physical safety concerns, the BIP should include a crisis protocol — what staff do when the behavior escalates, who is called, and what de-escalation steps are taken before any physical intervention.

8. Data collection and monitoring plan. Who collects data, how often, in what format, and who reviews it? The BIP is a live document — if the data shows the behavior is not decreasing, the plan should be revised.

Who Develops the BIP in Colorado

The BIP is developed by the IEP team, but the technical expertise for behavior support varies across Colorado's Administrative Units. In well-resourced districts, a Board Certified Behavior Analyst (BCBA) may conduct the FBA and write the BIP. In rural BOCES districts, a school psychologist or district behavior specialist typically fills this role.

Parents are IEP team members and have the right to participate in the development of the BIP. If the school presents you with a completed BIP at the IEP meeting and asks you to sign off, that is a problem — the BIP should be developed collaboratively, not presented as a fait accompli. You can request a draft in advance or ask to participate in the BIP development meeting before the formal IEP meeting.

If you have a private BCBA working with your child at home or in a clinic, invite them to the IEP meeting to contribute to or review the BIP. Private assessors cannot impose their recommendations, but the IEP team must consider them.

For Students With Autism and Communication Barriers

When a student with autism uses behavior as communication — because verbal communication is unavailable or insufficient in the moment — the BIP must address communication access as the primary intervention. A BIP that ignores AAC and focuses only on behavioral consequences is missing the root cause.

In these cases, the replacement behavior is often an AAC response: pressing a button, pointing to a symbol, using a break card. The BIP must specify the communication modality, where the communication device or symbols will be available, and how staff will prompt and reinforce its use. A BCBA or augmentative communication specialist should be involved in developing this component.

BIP vs. School-Wide Discipline Policy

Colorado parents sometimes encounter a school that says "the BIP doesn't override our school policy" when trying to use the BIP as a shield against suspension or exclusion. This is legally incorrect when the behavior is a manifestation of the disability.

If the IEP includes a BIP and the behavior in question is addressed by that BIP, the school must follow the BIP's procedures before defaulting to school-wide discipline. If a student with a BIP for elopement is suspended for elopement because staff didn't implement the antecedent strategies or didn't use the break procedure the BIP prescribes, that is an IEP implementation failure — not a legitimate application of school policy.

When the BIP Isn't Being Implemented

This is the most common problem. The BIP is written, placed in the IEP, and then ignored in practice. Antecedent strategies aren't happening. Staff don't know the replacement behavior protocol. Crisis procedures aren't followed. Data isn't being collected.

What to do:

1. Document specific instances where the BIP was not followed — dates, what was supposed to happen, what actually happened
2. Contact the special education case manager in writing and ask for confirmation that all staff implementing the BIP have been trained on its procedures
3. Request a BIP review meeting if the behavior is not decreasing or is escalating
4. If documentation shows a pattern of non-implementation, file a state complaint with the CDE ESSU for failure to implement the IEP

Under ECEA, compensatory education is available when service failures — including BIP non-implementation — result in lost educational benefit. That is a potential remedy for students whose behavioral needs were not being addressed as required.

Sample BIP Structure for Colorado Families

This is a framework you can use to evaluate the BIP your district proposes:

If the answer to either column is no for more than one row, the BIP needs revision before you sign the IEP.

The Colorado IEP & 504 Blueprint includes a full BIP evaluation checklist, the ECEA framework for behavioral supports, and documentation templates for escalating when BIPs aren't being implemented as written.

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