Functional Behavior Assessment in Texas: What the ARD Must Do and When

Your child is getting written up, being sent to the office, or missing class because of behavior the school is treating as a discipline problem. You want the school to understand why the behavior is happening — not just react to it. A Functional Behavior Assessment (FBA) is how that understanding gets built. In Texas, the ARD committee and FBA process have specific rules that determine when one is required and what it must produce.

What an FBA Actually Is

A Functional Behavior Assessment is a structured evaluation process that identifies:

1. The specific behavior(s) of concern — defined in observable, measurable terms (not "disruptive" but "leaves seat and shouts during transitions, occurring approximately 8 times per day")
2. The antecedents — what happens immediately before the behavior that may be triggering it
3. The function of the behavior — why the child is doing it (to escape a difficult task, to get attention, to gain sensory input, to communicate frustration or confusion)
4. The consequences — what happens after the behavior that may be reinforcing it

The function is the critical piece. A child who throws things to escape difficult academic work needs a completely different intervention than a child who throws things to get peer attention. An FBA that does not identify function is not a real FBA — it is a behavior log.

When Texas Requires an FBA

Under IDEA and Texas's implementing rules in TAC Chapter 89, an FBA is required in two situations:

1. Discipline resulting in a change of placement: When a child with a disability is disciplined in a way that results in a change of placement — typically more than 10 cumulative school days of removal, or a pattern of shorter removals — the district must, if it has not already done so, conduct a Functional Behavior Assessment and develop or review a Behavior Intervention Plan (BIP). This requirement is triggered at the manifestation determination meeting.

2. When behavior impedes learning: IDEA requires that the IEP team (in Texas, the ARD committee) "consider, when appropriate, strategies, including positive behavioral interventions and supports, and other strategies, to address that behavior" when a child's behavior impedes their learning or the learning of others. While this does not automatically require an FBA, it creates the foundation for requesting one.

Texas parents can also request an FBA at any time as part of a special education evaluation, just as they would request any other component of the FIIE. If behavior is a suspected area of disability or is a documented area of concern, the FBA request can be included in a written evaluation request.

Who Conducts FBAs in Texas

In most Texas ISDs, FBAs are conducted by:

• LSSP (Licensed Specialist in School Psychology) — the most qualified professional for complex behavioral assessment, including direct observation, indirect assessment (teacher/parent interviews), and rating scales
• Board Certified Behavior Analyst (BCBA) — particularly for autism-related behaviors
• Behavioral Specialist or Behavior Support Specialist employed by the district or ESC

The person conducting the FBA should have direct knowledge of behavioral principles and functional analysis methodology. A teacher completing a behavior checklist is not an FBA. An administrator reviewing incident reports is not an FBA.

If the district's FBA was inadequate — for example, it identified the topography of the behavior but not its function — you can request an independent FBA as part of an IEE request.

What a Compliant FBA Should Produce

A thorough FBA in Texas should result in a written report that includes:

• A precise, observable definition of the target behavior(s)
• A summary of data collection methods (direct observation, A-B-C data, structured interviews with teachers and parents, record review)
• Identified antecedents and setting events (including academic demands, transitions, sensory environment, time of day)
• A clear hypothesis about the function of the behavior
• A summary of previous interventions and their outcomes

This report then drives the Behavior Intervention Plan (BIP). An FBA report that does not conclude with a functional hypothesis cannot support a meaningful BIP — because the BIP strategies must directly address the function, not just the behavior itself.

From FBA to Behavior Intervention Plan

Once the FBA is complete, the ARD committee develops or revises the BIP. In Texas, the BIP must be embedded in or attached to the IEP and must be implemented by all staff who work with the child. A BIP should include:

• Prevention strategies — changes to the environment or instruction that reduce the likelihood of the behavior occurring (modifying task difficulty, building in choice, changing seating)
• Replacement behavior teaching — what the child should do instead of the problem behavior, and how they will be explicitly taught and reinforced for doing it
• Response strategies — how staff will respond consistently when the behavior occurs and when the replacement behavior occurs
• Crisis plan — if the behavior includes safety concerns, a documented protocol for de-escalation

Watch out for BIPs that are essentially punishment plans — a list of consequences for the behavior without any replacement behavior instruction or antecedent modification. Under IDEA's positive behavioral interventions and supports (PBIS) requirement, a BIP that only describes consequences is legally insufficient.

When the School Refuses or Delays an FBA

If the ARD committee refuses to conduct an FBA despite documented behavioral concerns, they must provide a Prior Written Notice (PWN) explaining why not. If the PWN cites insufficient evidence of behavioral impact on learning, gather documentation: discipline logs, teacher emails, incident reports, and any private-provider behavioral assessments.

If the school agrees to conduct an FBA but the resulting report is inadequate or does not identify function, you can:

1. Request that the ARD reconvene to review the FBA and explain how it will support the BIP
2. Request an IEE that includes a functional behavior assessment component
3. File a TEA state complaint if the district refuses to conduct an FBA after a change-of-placement discipline event — this is a clear procedural violation

The Texas IEP & 504 Blueprint includes FBA request language, ARD checklist questions for reviewing FBA results, and templates for documenting when behavior-related procedural requirements are not being met.

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