Functional Behavior Assessment in Arkansas: What It Is and How to Request One

Your child's behavior is disrupting their learning — or the school is using behavior as a justification to remove them from the classroom more often than you think is appropriate. In both situations, the right tool is a functional behavior assessment (FBA). Here is how FBAs work in Arkansas, when you can request one, and what should come out of it.

What a Functional Behavior Assessment Is

A functional behavior assessment is a structured process for understanding why a student engages in a specific problem behavior — what function that behavior serves. Behavior always has a function: avoiding something aversive (escape), getting access to something desirable (attention, tangibles), sensory stimulation, or communicating something the student cannot express verbally.

An FBA is not a disciplinary tool. It is an analysis. The output of a well-conducted FBA is a hypothesis about what is driving the behavior, supported by observational data and records review. That hypothesis directly informs the behavioral intervention plan (BIP) — which is the actual document describing how the school will respond to and prevent the behavior.

Without an FBA, a BIP is guesswork. Schools sometimes write BIPs that simply describe consequences without analyzing the underlying function. Those plans rarely work.

When Arkansas Schools Must Conduct an FBA

Under 34 C.F.R. § 300.530 and Arkansas DESE rules, when a disciplinary removal constitutes a change of placement — including a removal beyond 10 consecutive school days — the team must address the behavior through an FBA/BIP process. After a manifestation determination review finds that the conduct was a manifestation of the student's disability, the IEP team must either conduct an FBA (unless the district already conducted one) and implement a BIP, or review and modify an existing BIP. Special-circumstances removals to an interim alternative educational setting for weapons, drugs, or serious bodily injury can last up to 45 school days and also require the team to address behavior through this process.

Outside these disciplinary situations, an FBA is permitted — and you can request one — whenever behavior is interfering with your child's learning or the learning of others. If your child's IEP addresses behavioral needs and the existing BIP is not working, you have grounds to request a new FBA.

How to Request an FBA

Submit a written request to the district's special education coordinator. State: "I am requesting a functional behavior assessment for [child's name] to inform revision of their behavioral intervention plan. The current behavioral strategies are not effectively supporting [child's] educational performance."

Keep a copy of your request. Ask the district to confirm in writing whether it will conduct the FBA and what consent process it will use. If the district refuses, request Prior Written Notice explaining why.

If the district refuses and you believe an FBA is warranted, you can file a state complaint with DESE or request that the team discuss the refusal in an IEP meeting.

What a Quality FBA Should Include

An FBA that will actually inform a useful BIP must include:

• Direct behavioral observation in the settings where the behavior occurs — typically the classroom, transitions, and any other relevant settings. Observations should be structured (using A-B-C recording: Antecedent, Behavior, Consequence) across multiple instances.
• Records review — cumulative file, prior evaluation data, disciplinary records, previous BIPs
• Interviews — with teachers, support staff, you as a parent, and (when appropriate) the student
• Operational definition of the target behavior — specific enough that two observers would independently agree on whether the behavior is occurring
• Frequency or intensity data — how often the behavior occurs, how severe, under what conditions
• Hypothesis statement — a clear, data-supported statement about the function of the behavior

A one-hour observation by a school counselor without systematic data collection is not an adequate FBA. If the FBA was part of a district evaluation and you disagree with that evaluation, you can request an Independent Educational Evaluation under 34 C.F.R. §300.502; the district must fund it or file due process to defend its evaluation.

What Should Come Out of an FBA: The BIP

The behavioral intervention plan that follows from the FBA should be function-matched. If the FBA found that your child's behavior functions to escape non-preferred academic tasks, the BIP should not only address consequences for the behavior — it should address the instructional environment that is triggering the behavior, build the student's capacity to tolerate or communicate about the demand, and provide appropriate escape mechanisms that do not reinforce avoidance.

A BIP in Arkansas should include:

• A description of the target behavior (observable, measurable)
• A summary of the FBA hypothesis
• Prevention strategies (environmental modifications, antecedent interventions)
• Replacement behaviors the student will be taught
• How the school will respond when the behavior occurs and when the replacement behavior occurs
• How the plan will be implemented consistently across settings and staff
• How implementation will be monitored and when the plan will be reviewed

When included in the IEP, a BIP is part of the IEP and its provisions must be implemented. If staff are not implementing it, that is an IEP implementation failure that can be documented and addressed.

Arkansas Context: Behavioral Challenges and Resource Availability

Arkansas's disability enrollment data shows that Other Health Impairment (which includes ADHD) appears among the five largest categories in the state prevalence data; students in Emotional Disturbance may also have behavior-related needs. Many students whose behavior triggers the need for an FBA fall into these categories. Access to Board Certified Behavior Analysts (BCBAs) varies significantly across Arkansas's 259 districts — rural districts often lack in-house BCBA capacity and may contract with outside providers who divide their time across multiple schools.

If your district does not have a BCBA on staff, ask who will conduct the FBA and what their credentials are. A qualified FBA evaluator should have training in applied behavior analysis, functional assessment methodology, and behavioral observation procedures.

The Arkansas IEP & 504 Blueprint includes guidance on requesting and evaluating FBAs, a checklist for reviewing BIP quality, and template letters for requesting behavioral evaluations — including how to document and challenge a BIP that is not being implemented consistently.

See more Arkansas guides →