Functional Behavior Assessment in Hawaii: What Parents Need to Know

When a child's behavior is getting in the way of their learning — or disrupting the learning of others — the HIDOE is supposed to conduct a Functional Behavior Assessment before resorting to punishment, placement changes, or disciplinary removal. If you're hearing the term FBA for the first time, or if you've been told one is needed for your child, here's what it means and what you should be doing as a parent.

What a Functional Behavior Assessment Is

A Functional Behavior Assessment (FBA) is a systematic process for figuring out the underlying purpose — or "function" — of a specific behavior. Behaviors don't happen randomly. A child who bolts from the classroom, melts down during transitions, or refuses tasks is communicating something. The FBA's job is to identify what that something is.

The four most common behavior functions are:

• Escape or avoidance — the behavior helps the child get out of something difficult or unpleasant
• Attention-seeking — the behavior reliably gets adult or peer attention
• Access to tangibles — the behavior results in getting a preferred item or activity
• Automatic reinforcement — the behavior itself is internally satisfying (sensory, self-stimulatory)

Knowing the function tells the IEP team what replacement behaviors to teach and what interventions are likely to work. An intervention that treats escape-motivated behavior as attention-seeking will fail — and may make the behavior worse.

When HIDOE Is Required to Conduct an FBA

Under IDEA and HAR Chapter 60, a Functional Behavior Assessment is required in several situations:

1. Discipline involving behavior that is a manifestation of disability — if the IEP team determines the behavior is related to the disability after a suspension exceeding 10 school days, the school must conduct an FBA and develop or revise a Behavior Intervention Plan (BIP).

2. When behavior impedes learning — if a student's behavior is affecting their own learning or the learning of peers, the IEP team must consider behavioral strategies, including whether an FBA is needed.

3. Before certain placement changes — when a significant change in placement is being proposed and behavior is a contributing factor.

4. When a parent or IEP team member requests it — you can request an FBA at any time, and the school must respond with either an agreement to conduct one or a Prior Written Notice (PWN) explaining why it's declining.

Parents in Hawaii should know that just because the school hasn't done one doesn't mean one isn't warranted. If your child is experiencing repeated behavioral incidents, is being sent home early, or has been suspended, request an FBA in writing.

What the FBA Process Looks Like in Hawaii

A thorough FBA is not a 30-minute observation. It involves multiple data collection methods across multiple settings, typically including:

• Direct observation — structured observation of the child in classroom settings, noting the antecedents (what happens before), behavior (what exactly occurs), and consequences (what happens after). This A-B-C analysis is the backbone of the FBA.
• Interviews — with parents, teachers, and other staff who interact with the child
• Record review — discipline records, incident reports, prior assessments, and IEP data
• Rating scales and checklists — standardized tools to quantify behavior patterns
• Functional Analysis (FA) — in complex cases, especially for students with autism or significant communication challenges, a trained BCBA may conduct a controlled functional analysis to experimentally identify behavior functions

In Hawaii, the HIDOE is increasingly using Registered Behavior Technicians (RBTs) and Board Certified Behavior Analysts (BCBAs) to conduct and oversee FBAs and implement resulting behavior plans. On neighbor islands, however, BCBAs are in critically short supply. The Big Island, Maui, Kauai, Molokai, and Lanai face chronic staffing gaps that can lead to delays in getting an FBA completed.

If you're on a neighbor island and the school tells you it can't conduct the FBA because there's no BCBA available, that is not a legal justification for failing to meet your child's needs. Put the delay in writing and escalate to your District Educational Specialist (DES) if it continues.

Reading and Using FBA Results

The FBA results in a summary report that identifies the target behaviors, the function of each behavior, and the antecedent conditions that predictably trigger them. This report should directly drive the Behavior Intervention Plan that follows.

As a parent, you should receive a copy of the FBA report. Review it carefully:

• Does it describe your child's actual behavior with specificity, or is it vague?
• Does the identified function match what you observe at home?
• Are the antecedents identified consistent with what teachers and you have reported?
• Does the report recommend specific replacement behaviors and intervention strategies, or does it just describe the problem?

A weak FBA that identifies "non-compliance" as the behavior and "attention" as the assumed function without solid data is not a legally sufficient basis for a BIP. You have the right to challenge the findings and request an Independent Educational Evaluation (IEE) if you believe the school's FBA was inadequate.

Hawaii-Specific Considerations: Physical Interventions

Hawaii has strict rules under Act 242 and related HIDOE policies about physical restraint and seclusion. These interventions are only permissible when there is imminent danger of physical injury or severe property damage. They must be a last resort, not a routine response to behavior.

If physical restraint is used with your child, the school must notify you verbally on the same day and in writing within 24 hours. If your child's BIP permits or encourages the use of restraint as a primary behavior reduction strategy, that plan needs to be challenged. A well-constructed BIP based on a thorough FBA should reduce the need for any physical intervention over time — not institutionalize it.

The Hawaii IEP & 504 Blueprint includes guidance on requesting an FBA in writing, reviewing FBA reports, and using the results to hold the HIDOE accountable for building a behavior intervention plan that addresses the root cause rather than just suppressing symptoms.

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