Functional Behavior Assessment in Tennessee: What It Is and What Should Happen Next

When your child's school says they need to conduct a Functional Behavior Assessment, parents often have a surface-level understanding — something about observing behavior — but not a clear picture of what the process should look like, who should be running it, or what it legally requires the school to do afterward.

Tennessee has specific regulatory requirements for FBAs that go beyond the federal baseline. Here's what the process should actually include.

What an FBA Is

A Functional Behavior Assessment is a systematic process for identifying the purpose a specific behavior serves for the student. The core principle is that behavior is communication. A student who disrupts class, refuses tasks, or becomes aggressive is communicating something — anxiety about academic demands, a need for sensory input, a way to escape a situation they can't manage, or something else entirely.

The FBA identifies:

• The antecedent — what triggers or precedes the behavior
• The behavior itself — defined with enough precision to be observable and measurable
• The consequence — what happens immediately after, which may be unintentionally reinforcing the behavior

Without understanding function, behavioral interventions are essentially guesswork. Punishing a behavior that the student uses to escape anxiety may increase the anxiety and worsen the behavior. The FBA prevents that cycle.

Tennessee's Regulatory Requirements for FBAs

Tennessee State Board Rule 0520-01-09-.24 governs FBAs and Behavior Intervention Plans. This rule requires that, to the extent possible, the FBA be led by a school psychologist or Licensed Behavior Analyst (LBA). This is a higher standard than many states impose — it's not simply a general education teacher observing the student.

The FBA must include:

• Direct observation of the student across multiple settings (classroom, cafeteria, hallways, transitions)
• Review of records — academic, disciplinary, medical history
• Structured interviews with teachers, parents, and (when appropriate) the student
• Review of existing data — office referral patterns, attendance records, work samples

The process must be thorough enough to produce a defensible hypothesis about why the behavior is occurring and what it achieves for the student.

When Schools Are Required to Conduct an FBA

There are two primary triggers in Tennessee:

1. When behavior is impeding learning. Under IDEA, if a student's behavior impedes their learning or the learning of others, the IEP team must address behavioral supports and services. This typically means conducting an FBA and developing a Behavior Intervention Plan (BIP) to address those behaviors. This can happen at any IEP meeting — it doesn't require a disciplinary crisis.

2. Following a Manifestation Determination Review (MDR). If a student with an IEP is subject to disciplinary removal exceeding 10 consecutive school days, or a series of shorter removals that constitute a pattern, and the MDR finds that the behavior was a manifestation of the disability, the school must conduct an FBA and implement (or revise) a BIP. This is federally mandated under IDEA, not optional.

If an FBA was already conducted and a BIP already exists, the team must review and revise the BIP rather than simply starting from scratch.

What the FBA Leads To: The BIP

The FBA feeds directly into a Behavior Intervention Plan. The BIP is a written document — typically a component of the IEP — that describes:

• Replacement behaviors: What the student should do instead of the problem behavior, serving the same function
• Antecedent modifications: Changes to the environment or routine that reduce triggers
• Teaching strategies: How the school will explicitly teach the replacement behavior
• Reinforcement strategies: How the school will positively reinforce the replacement behavior
• Staff response protocols: What all staff should do when the problem behavior occurs — consistently, across all settings

Under Tennessee Rule 0520-01-09-.24, the BIP must be reviewed and revised at least annually. If a student's behavior significantly changes, or if the BIP strategies aren't working, the team should reconvene before the annual review.

Red Flags in the FBA Process

Not all FBAs are conducted with the rigor they should be. Watch for these problems:

The FBA is too brief. A legitimate FBA requires direct observation across multiple settings over multiple days. An FBA written in a single afternoon is unlikely to identify the true function of the behavior.

The FBA only describes the behavior, not its function. The deliverable is not "Johnny hits when frustrated." The deliverable is "Johnny hits to escape non-preferred tasks because he lacks the verbal communication skills to request a break" — and that distinction drives the entire BIP.

The BIP relies exclusively on punishment. An FBA-informed BIP should lead primarily with antecedent modifications and teaching replacement behaviors. A BIP that is essentially a list of consequences for misbehavior is not function-based and is unlikely to work.

No data collection system. A BIP without a plan for collecting ongoing data is a document without accountability. The BIP should specify how the school will track whether the replacement behavior is increasing and the problem behavior is decreasing.

Staff training is absent. A BIP is only effective if every adult in the student's environment implements it consistently. If the plan doesn't include training for all staff who interact with the student, implementation fidelity will be poor.

What Tennessee's 2025 OREA Report Found

A 2025 report by the Tennessee Comptroller's Office of Research and Education Accountability documented a significant problem with behavioral supports in Tennessee schools: administrators repeatedly calling parents to pick up students with behavioral disabilities — what the report calls "informal removals" — instead of implementing the behavioral supports mandated by their IEPs. These unrecorded removals bypass IDEA protections, cause learning loss, and disproportionately affect low-income families.

This pattern occurs in part because schools lack FBA-trained personnel, particularly in rural districts. If your child is being sent home repeatedly without formal disciplinary documentation, that is a procedural violation, and the school's obligation to conduct an FBA and implement a BIP exists regardless of whether they record the behavior formally.

Your Rights When You Disagree with the FBA

Just like a psychoeducational evaluation, you can request an Independent Educational Evaluation of a Functional Behavior Assessment if you disagree with its findings or methodology. The district must then either fund an independent FBA by a qualified outside professional or file for due process to defend their assessment.

If the FBA is being used to justify a change in placement or significant changes to services, request it in writing and request a Prior Written Notice (PWN) explaining the district's rationale.

For a complete walkthrough of how behavioral supports fit into the IEP structure — including sample BIP frameworks and what to ask at your next meeting — the Tennessee IEP & 504 Blueprint covers this in detail alongside the state's specific regulatory requirements.

The Bottom Line

An FBA is not just a paperwork requirement. Done correctly, it's the diagnostic tool that makes everything else in the BIP actually work. If your child's school is conducting one, you have the right to be informed of the process, participate in it, and receive a copy of the results before the IEP meeting. If what you receive doesn't describe function — not just behavior — push back.

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