Functional Behavior Assessment in Vermont: What Parents Need to Know

Your child is being suspended repeatedly. Or the school is talking about a more restrictive placement. Or the IEP team keeps listing "behavioral concerns" without doing anything systematic about them. A Functional Behavior Assessment is the tool that's supposed to answer why a behavior is happening — and a Behavior Intervention Plan is what comes next. Here's how both work in Vermont, and where parents can push for more.

What a Functional Behavior Assessment Actually Does

A Functional Behavior Assessment (FBA) is a structured process to identify the root cause — the "function" — of a specific problematic behavior. It doesn't just describe what the behavior looks like. It identifies what triggers it, what environmental factors maintain it, and most importantly, what the behavior is communicating or achieving for the child.

Behaviors almost always serve a function: getting something (attention, a preferred activity, sensory input) or avoiding something (a task, a sensory experience, social interaction). Without understanding the function, any intervention is guesswork.

An FBA typically involves:

• Direct observation of the child in school settings
• Review of records, existing data, and prior evaluations
• Interviews with teachers, parents, and the child (when appropriate)
• Analysis of antecedents (what happens before the behavior), behaviors (what the behavior looks like), and consequences (what happens after)

When Is an FBA Required in Vermont?

Vermont Rule 2360 requires IEP teams to consider positive behavioral interventions and supports — including an FBA — whenever a student's behavior impedes their learning or the learning of others.

Two specific triggers create a stronger obligation:

Suspension threshold: If a child with an IEP or 504 Plan is suspended for more than 10 cumulative or consecutive school days in a year, the school must conduct a manifestation determination. If the behavior is determined to be a manifestation of the disability (meaning caused by the disability or the school's failure to implement the IEP), an FBA must be conducted — or if one already exists, it must be reviewed and updated. A Behavior Intervention Plan must then be developed or modified.

Disciplinary change of placement: If a disciplinary action constitutes a change in educational placement, the same FBA and BIP obligations apply.

Parents do not have to wait for a crisis. If your child's behavior is interfering with their learning — even without suspensions — you can request an FBA as part of the IEP process. Put the request in writing.

What Makes a Good FBA

The quality of FBAs varies significantly. A poor FBA is completed by a single person reviewing cumulative records and filling out a form. A good FBA involves:

• Direct observation across multiple settings (classroom, lunch, specials, transitions)
• Input from multiple sources including parents
• Analysis of patterns, not just incidents
• Clear identification of the specific function of the behavior
• Baseline data that can be used to measure intervention effectiveness

In Vermont, specialists conducting FBAs may be school psychologists, board-certified behavior analysts (BCBAs), or licensed special educators. Given Vermont's staffing shortages, districts sometimes use contracted providers from outside the district. If you believe the person conducting the FBA lacks the expertise to assess your child's specific needs, you can raise this concern and request a more qualified evaluator.

The Behavior Intervention Plan

Once the FBA identifies why the behavior is happening, the Behavior Intervention Plan (BIP) provides the response framework. A BIP is not a punishment schedule. It is a teaching plan.

An effective BIP includes:

Prevention strategies: Changes to the environment or routine that reduce the likelihood the behavior occurs. If a child's behavior function is avoiding a particular task, the antecedent strategy might involve breaking that task into smaller steps, offering choice within the task, or providing advance warning before transitions.

Replacement behaviors: An explicit skill the child is taught to use instead of the problematic behavior — one that achieves the same function. If a child throws materials to escape a task, they need to learn a functional communication replacement (raising a hand, using a break card) that achieves the same escape but in an acceptable way.

Response procedures: How staff should consistently respond when the behavior occurs, to avoid accidentally reinforcing it.

Data collection: Specific metrics to track whether the intervention is working, with review timelines built in.

How to Use a BIP Template

Generic BIP templates — the kind circulated widely online — can provide structure but often fall short because they are not built from a specific child's FBA data. The function drives everything. A BIP for a behavior maintained by sensory avoidance looks entirely different from one for attention-maintained behavior.

Use any template as a starting point for data organization, but require that the plan's strategies be derived specifically from the FBA findings. If the BIP doesn't reference the identified behavior function, it's not a real BIP — it's a generic behavioral management checklist dressed up as one.

Vermont-Specific Challenges

Vermont's rural geography and staffing shortages mean that specialized behavioral support — particularly from BCBAs — may be limited in your district. Vermont Rule 2360 is clear that staffing shortages do not excuse a district from meeting its obligations. If an FBA requires a level of expertise the district doesn't have on staff, they must contract with external providers.

Vermont also places a strong emphasis on inclusive practices — 82% of Vermont students with IEPs spend most of their day in general education. This is positive, but it means BIPs must be implementable in general education settings, not just in self-contained rooms. Teachers need training on the specific plan, not just a copy of the document.

What Parents Can Do Right Now

If your child's current IEP mentions behavioral concerns but there is no FBA and no BIP, request both in writing. If a BIP exists but it's not working — if the same behaviors persist and no data review has happened — request an IEP team meeting to discuss revising the plan based on current data.

The Vermont IEP & 504 Blueprint includes tools for tracking behavioral data and a framework for evaluating whether a BIP is adequately tied to FBA findings, designed specifically for Vermont's school system.

An FBA is not the school's favor to grant. It is part of the obligation to provide a Free Appropriate Public Education when behavior is interfering with that education. Push for it in writing.

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