Functional Behavior Assessment in South Dakota: What It Is and When Schools Must Do One

Your child was suspended after a behavioral incident at school. Or the IEP team is proposing a more restrictive placement because the current one "isn't working." Or you keep hearing that your child's behavior is disrupting the classroom, but no one can tell you why it's happening or what the school has actually done to address it. In all three situations, the appropriate first step is the same: a Functional Behavior Assessment.

An FBA is not a punishment and it is not a disciplinary tool. It is a data-gathering process that tries to understand the function — the purpose — that a behavior serves for the child. Without that understanding, any intervention the school puts in place is essentially a guess. South Dakota law requires schools to conduct FBAs in specific circumstances, and knowing when to demand one is one of the most important skills an advocate parent can have.

What a Functional Behavior Assessment Actually Is

An FBA is a structured analysis of a student's challenging behavior aimed at identifying why the behavior occurs — the triggers, the setting conditions, and the need the behavior is meeting for the child. The underlying principle is that all behavior is purposeful. A child who runs out of the classroom is not simply being defiant; they are escaping something — a task that is too difficult, a sensory environment that is overwhelming, or an interaction that feels threatening. A child who disrupts instruction repeatedly may be seeking attention, avoiding difficult work, or communicating frustration they cannot express verbally.

A rigorous FBA involves several data-collection methods: direct observation of the student in the environment where the behavior occurs, structured interviews with teachers, parents, and the student (where appropriate), review of existing records and prior behavioral data, and analysis of antecedent-behavior-consequence (ABC) patterns. From this data, the evaluator develops a hypothesis about the function of the behavior — typically escape/avoidance, attention-seeking, access to a preferred item or activity, or automatic reinforcement (sensory input).

The FBA process results in a written report that documents the behavior of concern with precision (frequency, duration, intensity), identifies the environmental triggers and maintaining consequences, states the hypothesized function, and sets the foundation for building a Behavior Intervention Plan.

When South Dakota Schools Must Conduct an FBA

Under ARSD 24:05:26 and the federal IDEA regulations South Dakota implements, there are two mandatory FBA triggers that parents need to know.

The first trigger is a manifestation determination finding. When a student's IEP team conducts a Manifestation Determination Review (MDR) — which is required within 10 school days of any disciplinary decision that constitutes a change of placement — and the team finds that the behavior was caused by or had a direct and substantial relationship to the disability, the district must immediately conduct a Functional Behavior Assessment if one has not already been done. The district must also implement or revise a Behavior Intervention Plan based on that FBA. This is a non-discretionary requirement.

The second trigger applies when behavioral needs are already part of the IEP. If a student's disability manifests as challenging behavior that impedes either their learning or the learning of others, the IEP must include behavioral supports. An IEP team that adds behavioral goals or a behavior intervention plan to a student's IEP without conducting a proper FBA first is building on an incomplete foundation. The IEP is a legal document; a behavioral goal without data behind it is difficult to measure and nearly impossible to defend if services break down.

Beyond these mandatory triggers, parents can request an FBA as part of a broader evaluation request at any time. If you believe the school has not adequately identified the function of your child's behavior, you can write to the special education director requesting that an FBA be included in a comprehensive evaluation. The standard evaluation consent and timeline rules apply: once you provide written consent, the district has 25 school days to complete the evaluation.

What a Quality FBA Looks Like — and What to Watch For

Many parents receive an FBA report that is thin, generic, or clearly based on minimal observation. In small or rural South Dakota districts, the person conducting the FBA is often a cooperative-assigned behavioral specialist who may only visit the district a few days per month. A one-time classroom observation lasting 20 minutes, combined with a brief teacher interview, is not a sufficient FBA — particularly for complex behavioral profiles.

A quality FBA should:

• Precisely define the target behavior in observable, measurable terms (not "aggressive" but "hits peers with open hand, two to eight times per day, during unstructured transitions")
• Document when and where the behavior occurs most and least frequently
• Identify the consistent antecedent conditions that precede the behavior
• Describe what happens immediately after the behavior — teacher responses, peer reactions, task removal
• Distinguish between different behaviors that may serve different functions
• State the hypothesized function with supporting data, not speculation
• Identify the student's strengths and preferred activities, which inform the replacement behavior plan

If the FBA report you receive is vague, if it describes your child in general terms without specifics, or if it identifies a function ("attention-seeking") without data to support that conclusion, you have standing to request an Independent Educational Evaluation of the behavioral assessment at public expense. The same IEE rules that apply to academic evaluations apply here.

From FBA to Behavior Intervention Plan

The FBA is only the first step. The output that actually changes what happens in the classroom is the Behavior Intervention Plan. Under ARSD requirements and the behavioral support provisions of IDEA, a BIP must be developed after an FBA identifies the function of behavior. The BIP should be included in or attached to the IEP document so that it has the same legal weight.

A strong Behavior Intervention Plan based on a South Dakota FBA should include:

Antecedent strategies — changes to the environment, schedule, or task demands that reduce the triggers identified in the FBA. If the FBA found that the behavior spikes during unstructured transitions, the BIP should specify structured transition routines, visual cues, and advance warnings.

Teaching replacement behaviors — the BIP must identify a Functionally Equivalent Replacement Behavior (FERB): a positive behavior that achieves the same function for the child as the problem behavior, but is socially appropriate. If the function is escape from a difficult task, the replacement behavior might be a self-advocacy request ("I need a break") taught explicitly and reinforced consistently.

Consequence strategies — how adults in the environment will respond when the replacement behavior is used (reinforcement) and when the problem behavior occurs (minimizing inadvertent reinforcement of the problem behavior).

Data collection protocols — how behavior will be tracked to determine whether the BIP is working. Progress monitoring of behavioral goals should appear in the IEP just like academic goal monitoring.

Crisis procedures — for students with behaviors that pose safety risks, the BIP should include a clear protocol for de-escalation and what staff will do if behavior escalates beyond the preventive strategies.

The Cooperative Specialist Challenge

In many South Dakota districts, particularly those served by cooperatives like the Black Hills Special Services Cooperative, the James Valley Education Cooperative, or the Oahe Special Education Cooperative, the person responsible for conducting FBAs and supporting BIP implementation is an itinerant behavioral specialist who may serve a dozen or more districts.

This creates a real implementation problem. A BIP that was written by a cooperative specialist who visits three times a year is only as effective as the local staff who carry it out daily. If general education teachers or paraprofessionals have not been trained on the BIP strategies, or if no one is collecting the behavioral data the plan requires, the BIP exists on paper but not in practice.

Parents have the right to ask specifically: Who is implementing the BIP daily? What training have those staff received? Who is collecting behavioral data? How often is that data reviewed, and by whom? If the answers reveal that no one is consistently implementing the plan, that is a FAPE concern — not just a logistical inconvenience.

If you are navigating a behavioral situation in your child's IEP and need a practical framework for requesting an FBA, understanding what should be in the resulting BIP, and knowing when to escalate, the South Dakota IEP & 504 Blueprint addresses these steps with South Dakota-specific administrative rules and tools for documenting what the district is or is not doing.

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