Functional Behavior Assessment in Montana: When to Request One and What It Must Include

Your child keeps getting sent to the office. They've been suspended twice this month. Or maybe the behavior isn't dramatic — they just shut down completely when asked to write, or they bolt from the classroom during transitions. The school is frustrated. You're frustrated. But nobody has sat down and asked the most important question: why is the behavior happening?

That question is exactly what a Functional Behavior Assessment is designed to answer. Here is how the process works in Montana, when the district is required to do one, and what parents in rural areas need to know about accessing qualified evaluators.

What an FBA Actually Does

A Functional Behavior Assessment is a systematic process for identifying the function — the purpose — that a behavior serves for a particular student. Behavior is communication. A student who hits during small group work may be communicating that the task is too difficult. A student who wanders around the classroom may be seeking sensory stimulation that sitting at a desk doesn't provide. A student who screams during transitions may be communicating anxiety about unpredictability.

Two students displaying identical behaviors can require completely different interventions if their behaviors serve different functions. An intervention designed for a student seeking escape from difficult tasks will fail — and may make things worse — if applied to a student whose behavior is driven by a need for sensory input.

A proper FBA includes:

• Direct observation of the student in multiple settings (classroom, specials, cafeteria, transitions, recess)
• Structured interviews with teachers, parents, paraprofessionals, and the student when appropriate
• Review of disciplinary records, existing IEP data, and any relevant psychological or medical evaluations
• Systematic data collection using ABC recording (Antecedent, Behavior, Consequence) across multiple days
• Analysis identifying the hypothesized function of the target behavior
• A written report documenting findings, function hypothesis, and recommendations for intervention

The FBA report is what drives the Behavior Intervention Plan (BIP). A BIP not grounded in an FBA is guesswork.

When Montana Districts Are Required to Conduct an FBA

Under IDEA and Montana's implementing regulations in ARM Title 10, Chapter 16, an FBA is required in specific circumstances:

After a manifestation determination. If the IEP team conducts a Manifestation Determination Review (MDR) and finds that the student's behavior was a manifestation of their disability — or resulted from the district's failure to implement the IEP — the district must conduct an FBA (if one doesn't already exist) and develop or revise a Behavior Intervention Plan. This is a non-discretionary requirement, not a recommendation.

When a student is placed in an Interim Alternative Educational Setting (IAES). When a student is removed to an IAES — following a serious discipline incident involving weapons, drugs, or a determination of substantial likelihood of injury — the district must conduct an FBA and implement a BIP designed to address the behavior that led to the removal.

When behavior is interfering with learning. Even outside of formal discipline situations, IDEA requires IEP teams to consider whether a student whose behavior is interfering with their learning (or the learning of others) needs a behavioral intervention plan. Montana's ARM rules implement this standard. In practice, "consider" should mean more than a perfunctory mention at an IEP meeting — if behavior is a documented pattern, the team should be assessing whether existing supports are adequate.

Requesting an FBA as a Parent

You do not have to wait for a disciplinary crisis to request an FBA. If your child's behavior is interfering with their education and the district hasn't proactively assessed it, submit a written request for an evaluation that specifically includes a functional behavior assessment. Frame it as part of a broader evaluation request under IDEA:

"I am requesting that the district conduct a comprehensive evaluation of [child's name] including a functional behavior assessment to assess all areas of suspected disability, including behavioral and emotional functioning."

Once you submit this in writing, the district must either respond with a consent form for evaluation or provide a Prior Written Notice explaining why it is refusing the evaluation request. The 60-calendar-day evaluation clock starts when you sign consent.

What a Behavior Intervention Plan Must Include

The BIP is the intervention document that flows from the FBA. A compliant BIP identifies the target behavior clearly, states the hypothesized function from the FBA, and specifies:

Antecedent strategies — modifications to the environment, schedule, or task demands that reduce the likelihood of the behavior occurring before it starts. If the function is escape from difficult reading tasks, antecedent strategies might include pre-teaching vocabulary, chunking assignments, or adjusting task difficulty.

Replacement behaviors — functionally equivalent behaviors that serve the same purpose for the student but are socially acceptable. If the function is attention-seeking, the replacement behavior might be a taught hand-raising protocol. Teaching the replacement behavior must be an active part of the BIP, not just an assumption.

Reinforcement strategies — how the student will be reinforced for using the replacement behavior. Reinforcement plans must be individualized to what actually motivates the student.

Response strategies — how staff will respond consistently when the target behavior occurs, in a way that does not inadvertently reinforce the function.

Implementation responsibilities — who is responsible for each component of the plan and across which settings. A BIP that applies in the special education room but not the general education classroom is not a comprehensive plan.

Progress monitoring — how the district will track whether the BIP is working. This should involve ongoing data collection, not a gut check at the next IEP meeting.

A BIP that lists only consequences ("warning, then office referral, then suspension") with no function analysis, no antecedent modification, and no replacement behavior teaching is not a behavior intervention plan. It is a discipline protocol.

The Rural Montana Challenge: Finding Qualified Evaluators

In large districts and urban areas, FBAs are often conducted by school psychologists who are employed by or contracted through the district. In rural Montana, the picture is more complicated.

Montana's 21 Special Education Cooperatives provide or coordinate services for member districts that can't staff their own specialists. Cooperative psychologists typically travel across multiple districts and conduct evaluations including FBAs. The challenge is caseload: a cooperative psychologist may cover dozens of schools across a wide geographic area. This can mean delays in scheduling evaluations and observations across multiple settings — which is a methodological necessity for a valid FBA.

Board Certified Behavior Analysts (BCBAs) are the gold standard for FBA evaluation, particularly for complex behavior cases. In Montana, BCBAs are concentrated in Billings, Missoula, and a few other larger cities. Many rural districts have no BCBA on staff and no BCBA contractor accessible through the cooperative.

Teletherapy and Remote Assessment

Montana has increasingly used teletherapy and remote service delivery to address the rural specialist shortage. For FBAs, remote observation has limitations — a psychologist cannot observe a student's behavior across settings through a camera the way they can in person. However, remote options can play a supporting role:

• Video documentation of specific behaviors, recorded by classroom staff and reviewed remotely by the evaluator
• Remote structured interviews with teachers, parents, and paraprofessionals
• Remote consultation with cooperative staff conducting in-person observations using standardized data collection tools

Some BCBAs and psychologists in Montana's larger cities will work with rural districts in a hybrid model — conducting remote intake and interview components and making targeted in-person observation visits rather than repeated travel. If your district's FBA is being delayed or compromised by staffing limitations, ask specifically what accommodations are being made to ensure the assessment covers multiple settings across multiple days.

Requesting an Independent FBA

If you believe the district's FBA was inadequate — conducted too quickly, in only one setting, by staff without behavioral assessment expertise, or without interview data from parents — you have the right to request an Independent Educational Evaluation of the behavioral assessment at public expense under ARM 10.16.3504. The process is the same as any other IEE request: submit a written request stating that you disagree with the FBA. The district must either fund an independent FBA or file for due process to defend its assessment.

An independent FBA by a BCBA provides a much more rigorous functional analysis and carries significant weight at IEP meetings and in dispute proceedings.

The Montana IEP & 504 Guide includes frameworks for requesting FBAs, reviewing BIP adequacy, understanding the manifestation determination process, and documenting behavioral incidents to support a state complaint — with Montana-specific ARM citations throughout.

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