Functional Behavior Assessment in Michigan: What Parents Need to Know Under MARSE

When a school responds to your child's behavior with suspensions, office referrals, or daily phone calls asking you to pick them up, they are treating a symptom rather than investigating a cause. A Functional Behavior Assessment (FBA) is the clinical tool that forces the school to do the harder work: figure out why the behavior is happening before deciding what to do about it.

Michigan parents have specific rights around FBAs under both IDEA and MARSE — rights that most schools do not advertise.

What a Functional Behavior Assessment Actually Is

An FBA is a structured evaluation process used to identify the function or purpose behind a student's challenging behavior. The fundamental premise is that all behavior communicates something: a need, an escape from something aversive, a bid for attention, or access to a preferred item or activity. If the school does not understand the function, any intervention it designs is a guess.

A properly conducted FBA typically includes:

• Direct observation of the student across multiple settings (classroom, hallway, cafeteria, transitions)
• Interviews with the student, teachers, parents, and other staff
• Review of records: discipline logs, attendance data, academic performance, and existing IEP goals
• Data collection on antecedents (what happens immediately before the behavior), the behavior itself, and consequences (what happens after)

The output is a written summary identifying the behavior, its function, and the conditions under which it occurs. That summary then drives the development of a Behavior Intervention Plan (BIP), which specifies evidence-based strategies to replace the problem behavior with an appropriate one.

When Michigan Schools Are Required to Conduct an FBA

MARSE and IDEA create clear triggers that obligate a Michigan school district to conduct an FBA:

Disciplinary removal beyond 10 school days. When a child is suspended or removed from their educational placement for more than 10 cumulative school days in a school year in a pattern that suggests exclusion, or faces a long-term removal, the district must conduct a Manifestation Determination Review (MDR). If the MDR finds the behavior is a manifestation of the disability — meaning the conduct was caused by the disability or was a direct result of the school's failure to implement the IEP — the district must conduct a functional behavior assessment if one has not been done already, and develop or revise the BIP.

When behavior impedes the student's learning or the learning of others. This language comes from IDEA Section 614(d)(3)(B)(i). It requires the IEP team to "consider the use of positive behavioral interventions and supports, and other strategies, to address that behavior." In practice, this means that any time a student's behavior is interfering with their education, the IEP team should be discussing an FBA. It is not limited to serious disciplinary incidents.

As part of an initial evaluation or re-evaluation. If a student's disability includes significant behavioral components — Emotional Impairment, Autism Spectrum Disorder, or Intellectual Disability, for example — an FBA should be part of the comprehensive evaluation. If the MET skipped it, you can request one as part of the evaluation process or request an Independent Educational Evaluation (IEE) that includes a behavioral component at public expense.

How to Request an FBA in Michigan

You do not need to wait for a crisis. Put the request in writing — email is fine, but keep a copy. Address it to the special education director, not just the classroom teacher. Your request should include:

• Your child's name and school
• A brief description of the behaviors you are observing at school and, if relevant, at home
• An explicit request for a Functional Behavior Assessment under IDEA and MARSE
• A request for Prior Written Notice (PWN) documenting the district's response within 10 school days

The PWN requirement is critical. Michigan law requires the district to issue written notice when it proposes or refuses to take an action. If the district verbally tells you "we don't think an FBA is necessary," that refusal needs to be documented in writing. A verbal denial is not a legal refusal. Demanding PWN turns informal stonewalling into a formal, documented decision you can challenge.

If the district refuses in the PWN, you have the basis for a State Complaint with the Michigan Department of Education Office of Special Education (MDE OSE), which must be investigated and resolved within 60 calendar days.

What Makes a Michigan FBA Inadequate — and What to Do About It

Not all FBAs are created equal. Schools sometimes conduct cursory assessments — a brief teacher interview and one observation — that do not meet the legal standard of being "comprehensive" and conducted by qualified personnel. Signs of an inadequate FBA:

• Observation conducted only in one setting (typically the classroom)
• No parent interview
• No direct data collection — conclusions based entirely on teacher reports
• Behavioral function identified as "attention-seeking" without evidence across settings
• No connection between the identified function and the proposed BIP strategies

If you believe the school's FBA was insufficient, you can request an IEE at public expense that includes a behavioral component. The district must either agree to fund the independent evaluation or file for due process to defend its own assessment. It cannot simply ignore the request.

How the FBA Connects to Your Child's IEP

The FBA is not a standalone document. Its findings must drive the behavioral goals in the IEP and the specific supports in the Behavior Intervention Plan. Under MARSE, if a student's IEP includes behavioral goals, those goals must be measurable and grounded in the functional data collected during the FBA.

Common misalignments to watch for:

• BIP strategies that address symptoms, not function. A student who acts out to escape overwhelming sensory input does not benefit from a reward chart for compliance. Escape-motivated behaviors require environmental modifications and sensory accommodations.
• BIP that exists in the document but not in practice. Request written confirmation from each teacher describing how and when BIP strategies are being implemented. If no one can describe what they are doing, the BIP is not being followed.
• Missing data on progress. The IEP must include a mechanism for measuring behavioral goal progress, and parents must receive progress reports on the same schedule as general education report cards.

Michigan school data shows that behavioral and disciplinary issues are among the leading reasons parents enter the advocacy space. Parents on Michigan special education forums describe situations where a six-year-old was suspended in the second week of kindergarten, or where a school repeatedly sent a child home — effectively denying FAPE — without ever conducting an FBA or considering whether specialized supports could address the behavior.

An FBA does not just protect your child during a disciplinary crisis. It creates the legal documentation trail showing the school knew about the behavior, had a plan, and was or was not implementing it. That paper trail matters if you ever need to pursue compensatory services or a State Complaint.

The Michigan IEP & 504 Blueprint includes templates for requesting an FBA in writing and documenting behavioral incidents at home in a format that supports your position at IEP meetings.

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