Functional Behavior Assessment in Wisconsin: What Parents Need to Know

Your child's school keeps sending home behavior reports. Suspensions are piling up. The IEP team is talking about a more restrictive placement. Before any of those decisions moves forward, you need to know about the functional behavior assessment — and why it is the document that changes the entire conversation.

What a Functional Behavior Assessment Actually Is

A Functional Behavior Assessment (FBA) is a structured problem-solving process that examines why a behavior is occurring. Rather than focusing on what a student is doing wrong, an FBA investigates the function — the underlying need or trigger — that the behavior is serving.

Behaviors generally serve one of four functions: getting access to something desirable (attention, a preferred activity, a tangible item), escaping or avoiding something aversive (difficult work, sensory discomfort, social demands), getting sensory input, or communicating a need the student cannot express otherwise.

Until the team understands the function, any behavioral support plan is guesswork. An FBA turns guesswork into data.

When Wisconsin Schools Are Required to Conduct an FBA

Under IDEA and Wisconsin's implementation through PI 11, an FBA is specifically triggered in two legal contexts:

1. Manifestation Determination Reviews (MDRs) When a student with a disability is subject to a change of placement due to disciplinary action — meaning 10 or more cumulative days of suspension in a school year, or an expulsion — the IEP team must conduct a Manifestation Determination Review. If the behavior is determined to be a manifestation of the disability, the team must conduct an FBA (if one has not already been completed) and develop or revise a Behavior Intervention Plan.

2. When behavior impedes learning More broadly, under IDEA, when a student's behavior impedes their learning or the learning of others, the IEP team must consider — as part of developing or reviewing the IEP — the use of positive behavioral interventions, supports, and strategies. An FBA is the tool that makes those strategies meaningful. Wisconsin DPI guidance reinforces that teams should not be writing behavioral goals or Behavior Intervention Plans without an FBA as the foundation.

Outside of these formal triggers, a parent can request an FBA as part of a special education evaluation request at any time. A written request for a comprehensive evaluation that includes behavioral assessment starts the 15-business-day clock under PI 11.

What the FBA Process Looks Like

A thorough FBA involves multiple data sources — not just observations during one class period. The evaluator typically:

• Reviews existing school records, behavior logs, and prior assessments
• Interviews teachers, parents, and (depending on age) the student
• Conducts systematic direct observations in multiple settings: academic, non-academic, structured and unstructured
• Analyzes antecedents (what happens right before the behavior), the behavior itself (defined in observable, measurable terms), and consequences (what happens immediately after)

This ABC — Antecedent, Behavior, Consequence — analysis is the core of the functional analysis. The evaluator uses it to form a hypothesis about the behavior's function, which then drives the support plan.

From FBA to Behavior Intervention Plan

An FBA without a Behavior Intervention Plan (BIP) is incomplete. The FBA is the diagnosis; the BIP is the treatment plan.

A well-constructed Wisconsin BIP includes:

• A clear, measurable definition of the target behavior (observable enough that two observers would agree it occurred)
• The hypothesized function of the behavior based on FBA data
• Antecedent strategies — changes to the environment, schedule, or triggers before the behavior occurs
• Teaching replacement behaviors — functionally equivalent behaviors that serve the same purpose through an acceptable means
• Consequence strategies — how adults will respond when the behavior occurs and when the replacement behavior occurs
• Data collection procedures and a progress monitoring schedule
• Crisis response protocols if the behavior poses safety risks

Notice what a BIP is not: a list of punishments. An evidence-based BIP teaches the student a new skill. Punitive plans that focus only on removing privileges or increasing consequences rarely reduce behavior long-term, and they do not address the underlying function.

The Most Common BIP Problem: Plans That Sit in a Drawer

The most frequently documented failure mode for behavior plans in Wisconsin is implementation fidelity — the plan is written, filed in the IEP binder, and never consistently used. DPI complaint investigations repeatedly cite cases where aides, substitutes, and classroom teachers were unaware a BIP existed, let alone trained on how to implement it.

As a parent, your BIP rights include:

• Receiving a copy of the completed FBA report and BIP
• Participating in developing the BIP at the IEP meeting
• Requesting data on how the target behavior is trending since the plan was implemented
• Requesting a team review if the plan is not producing improvement within a reasonable timeframe

If the district implemented a change in placement — moved your child to a more restrictive setting — because of behavior, but never conducted an FBA, ask in writing whether an FBA was completed and when. A placement decision made without behavioral data may not reflect the Least Restrictive Environment analysis required under IDEA.

Milwaukee Public Schools: A Cautionary Data Point

State monitoring data for the 2024–2025 school year found that while students with IEPs make up less than 25% of the Milwaukee Public Schools student population, they accounted for 64% of students subjected to seclusion and 59% of students physically restrained. DPI has placed MPS under a corrective action plan requiring reform of its behavioral support practices.

This is an extreme example, but it illustrates what happens when behavioral interventions focus on control rather than function. If your child's school is reaching for seclusion, restraint, or escalating suspensions, an FBA and a properly implemented BIP are the legal tools available to redirect that approach.

The Wisconsin IEP & 504 Blueprint includes a behavioral support section that walks through what an FBA should contain, how to evaluate whether your child's BIP is legally adequate, and the exact questions to ask when the team is recommending a more restrictive placement based on behavior.

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