Behavior Intervention Plans in DC Schools: What DCPS and Charters Must Provide

If your child's behavior at school is resulting in disciplinary removals, restricting their ability to access instruction, or creating ongoing conflict with staff, a Behavior Intervention Plan (BIP) may be the most important document in their IEP. DC parents often don't realize that they can request an FBA and BIP directly — the school does not have to initiate this on its own, and waiting for a crisis to force the issue usually means months of lost instructional time first.

When DC Schools Must Conduct an FBA and Write a BIP

IDEA and DC's 5-A DCMR establish specific circumstances where an FBA (Functional Behavior Assessment) and BIP are required:

Mandatory in disciplinary contexts:

• When a student's IEP placement is changed due to a disciplinary action (suspension exceeding 10 cumulative days or removal to an interim alternative placement), IDEA requires the IEP team to conduct an FBA and implement a BIP if one is not already in place
• At a manifestation determination review (MDR), if the behavior is found to be a manifestation of the disability, the school must implement the BIP or modify an existing one

Best practice that DC families can demand:

• When a student's behavior is impeding their learning or the learning of others, the IEP team must consider behavioral supports, strategies, and interventions under IDEA §614(d)(3)(B)(i). This language is interpreted broadly — if recurring behavioral patterns are documented in teachers' notes, office referrals, or discipline records, you can request an FBA as part of the IEP process

To request an FBA, write to the special education coordinator: "I am requesting that the IEP team conduct a Functional Behavior Assessment to address behaviors that are impeding [student's] access to educational programming." This triggers the AED/evaluation process under DC's 5-A DCMR timeline.

What a Compliant FBA Must Include

A Functional Behavior Assessment is a data-gathering process — not a checklist or a one-time observation. A proper FBA involves:

• Direct observation of the student in the settings where the behavior occurs (classroom, hallway, lunch, transitions)
• Indirect assessment: interviews with teachers, parents, and the student (when appropriate); review of records and discipline data
• A-B-C analysis: documentation of Antecedents (what happens before the behavior), Behaviors (specific, observable description), and Consequences (what happens after)
• Hypothesis about function: identification of the function the behavior serves for the student — typically attention-seeking, escape/avoidance, sensory regulation, or tangible access

DC's 2025-2026 IEE rate schedule caps FBA at $1,200 for a public-expense independent FBA if you disagree with the school's assessment. A school-conducted FBA that consists only of a single observation form and a brief teacher interview is likely insufficient — particularly for students with complex behavioral presentations.

What a DC BIP Must Contain

The BIP follows directly from the FBA. It is a written intervention plan, incorporated into the IEP or attached to it, that includes:

• Clear description of the target behavior (specific and observable — "hits peers when directed to transition" not "aggression")
• Hypothesis about the function of the behavior, derived from the FBA
• Proactive strategies designed to prevent the antecedent conditions that trigger the behavior
• Teaching strategies to build replacement behaviors — the skill the student uses instead
• Reactive strategies — what adults do when the behavior occurs (must not include undefined exclusionary responses)
• Data collection plan — how the school will track whether the BIP is working and how often data will be reviewed
• Crisis plan if the behavior poses safety risks

A BIP that consists only of reactive consequences ("student will be removed to the office if...") without proactive and teaching components is not a compliant behavior intervention plan — it is a discipline plan.

Charter School BIP Compliance in DC

DC charter schools have an uneven track record with BIPs. As independent LEAs, they must conduct FBAs and implement BIPs under the same IDEA standards as DCPS, but oversight by individual charter boards varies significantly. OSSE's state complaint data consistently shows behavioral service failures among charter school special education complaints.

Common charter school BIP failures:

• BIP is written but staff are not trained to implement it
• BIP is implemented inconsistently across teachers and settings
• BIP relies on exclusionary responses (removal to hallway, office referrals) rather than functional behavioral strategies
• BIP data is not being collected, so there is no evidence base for revision

If the school wrote a BIP that is not being consistently implemented, request a data review meeting. Ask to see the data collection records. If the school cannot produce them, that is a FAPE implementation failure that you can raise through an OSSE state complaint.

Using DC's 10-Day Rule and Manifestation Determinations

When a student with a disability is suspended for 10 or more cumulative days in a school year, the school must:

1. Conduct a manifestation determination review (MDR) to assess whether the behavior was caused by or substantially related to the disability
2. If manifestation is found: implement or modify the BIP and return the student to their placement (unless an interim alternative placement is agreed or ordered)
3. If no manifestation: standard discipline procedures apply, but FAPE must still be provided

If your child does not have a BIP when a suspension reaches 10 days, you should be demanding both an MDR and an FBA request simultaneously. DC's ODR assigns impartial hearing officers within 2 business days for expedited due process hearings in discipline cases.

When the BIP Isn't Working: Requesting a Review

A BIP must be reviewed when data shows it is not achieving the intended outcomes. You can request a BIP review meeting at any time — you do not have to wait for the annual IEP review. Send a written request to the special education coordinator noting the specific behavioral data showing the current plan is ineffective and requesting a team meeting to review and revise the FBA and BIP.

If the school refuses to review the BIP despite evidence that it is not working, that refusal may constitute a failure to provide a free appropriate public education. That is an appealable issue through OSSE's complaint process.

The District of Columbia IEP & 504 Blueprint includes a BIP review checklist, an FBA request letter template, and guidance on how to document behavioral incidents to build the record for a complaint or hearing.

For general information on FBAs and BIPs, see our functional behavior assessment guide and behavior intervention plan guide.

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