Why FBAs Should Be Legally Required Before Any BIP (and what that means)

Does your child:

• Refuse to do work or walk out of class?

• Cry, yell, or shut down when overwhelmed?

• Throw things, hide under desks, or lash out?

If so, you’ve probably been told the school will write a Behavior Intervention Plan — or “BIP.”

It sounds helpful, right?

Except here’s the problem: most BIPs are written without a Functional Behavior Assessment — or “FBA.”

And that’s the step that actually explains why those behaviors are happening.

Right now, schools can legally skip that step.

But they shouldn’t.

Because a BIP without an FBA isn’t a plan — it’s a guess.

Let’s Start with What These Terms Mean

FBA (Functional Behavior Assessment)

An FBA is the process schools use to figure out why a child is showing certain behaviors.

It looks for patterns — what’s happening before, during, and after the behavior — and identifies what your child might be trying to communicate.

It’s not about punishment or blame.

It’s about understanding what’s underneath the surface.

An FBA answers the question:

“What is my child trying to say with this behavior?”

BIP (Behavior Intervention Plan)

A BIP is a written plan that comes after the FBA.

It lists strategies teachers and staff will use to support your child.

It should include:

• What triggers to avoid

• What calming or coping strategies help

• How staff will respond when behaviors happen

• What positive behaviors will be taught

The goal of a BIP isn’t control — it’s support.

The Problem: Schools Can Write a BIP Without a FBA

And this is where things fall apart.

A BIP written without an FBA is like writing a prescription without an exam.

It might sound official, but it’s missing the most important part — understanding the why.

Without the FBA, the school is reacting to the behavior instead of understanding it.

That’s why so many plans fail.

The Leaky Roof Metaphor

Think of it like this:

Writing a BIP without doing an FBA is like repainting your ceiling every time water stains appear — instead of fixing the leak.

Sure, it looks better for a little while.

But the next storm comes, and the stains show up again — worse than before.

The same thing happens with behavior.

If we don’t address what’s underneath — the fear, frustration, sensory overload, or unmet need — we’re just cleaning up the surface every time it rains.

Eventually, the roof caves in.

An FBA is what finds the leak.

The BIP is how you fix it.

You need both, or nothing changes.

When an FBA Should Be Done

An FBA should be completed when:

• A student’s behavior is getting in the way of learning

• The child is being sent home, suspended, or removed repeatedly

• The behavior seems linked to frustration, communication, or sensory needs

• The parent requests one

And yes — you can request one.

If you suspect your child’s behaviors are misunderstood, you can say:

“I’d like to formally request a Functional Behavior Assessment to better understand my child’s needs and create effective supports.”

Put it in writing — an email is fine — and keep a copy.

What Challenging Behavior Really Means

“Challenging behavior” doesn’t mean “bad kid.”

It means the behavior is challenging for the environment.

Here are some examples:

• Refusal to follow directions

• Shutting down or crying

• Running away or hiding

• Throwing objects or hitting

• Refusing work or saying “no” repeatedly

Those aren’t random acts of defiance — they’re communication.

A child might be saying:

“This is too hard.”

“This is too loud.”

“I don’t understand.”

“I need a break.”

A Real Example

One of my children used to throw handfuls of rocks at therapists.

He’d hide under desks and completely shut down.

Was he a bad kid? No.

He was communicating.

Throwing rocks wasn’t aggression — it was fear and overwhelm.

It was his way of saying, “I can’t do this right now.”

But to adults who didn’t understand, it looked like defiance.

That’s what happens when we react to the behavior instead of reading it.

An FBA would have told his story better than he could in words.

Why Children Hide

When a child hides — under a desk, behind furniture, in a corner, under a blanket — they aren’t trying to be difficult.

They’re trying to feel safe.

Hiding is a stress response, not a behavior problem. It’s what the body does when it feels unsafe or overstimulated — the “flight” part of the fight-flight-freeze-fawn cycle.

Here’s what might be driving it:

1. Sensory Overload

The classroom might be too loud, too bright, or too busy. Hiding helps block sound and visual input — it’s a form of self-regulation.

2. Emotional Overwhelm

Some kids feel big emotions but don’t yet have the skills to express them. Hiding is how they protect themselves from emotional overflow.

3. Social or Communication Fatigue

For children who struggle with communication or social interaction, hiding gives them a quiet break from constant social demands.

4. Shame or Fear of Failure

Kids who are anxious or perfectionistic often hide when they feel embarrassed, corrected, or incapable. It’s an attempt to disappear rather than disappoint.

5. Loss of Control

When everything feels unpredictable — transitions, new people, unfamiliar rules — hiding becomes one of the few things they can control.

What Hiding Is Really Saying

“I don’t feel safe.”

“I’m overwhelmed.”

“I need space.”

“Please stop pushing.”

Hiding is communication.

And if it happens often, that’s a clear signal an FBA is needed — not punishment.

Why FBAs Should Be Required

Here’s the truth:

A BIP without an FBA is almost always ineffective — not because teachers don’t care, but because they’re missing the information they need to actually help.

Right now, the law only requires an FBA in certain situations — like when a child faces suspension and their behavior might be related to their disability (called a “manifestation determination”).

But that’s not enough.

Waiting until a child is punished to understand them is backwards.

If the goal of special education is support, then an FBA should be a legal requirement before any BIP is written — not an optional step.

Why This Matters

Without an FBA, the school is left to guess:

• “Let’s try taking away recess.”

• “Let’s give more breaks.”

• “Let’s add a reward chart.”

But those are surface fixes.

Behavior is never random.

It’s always communication.

Skipping the FBA means skipping the conversation your child is desperately trying to have — in the only way they know how.

The Bottom Line

• FBA = Finds the WHY

• BIP = Creates the HOW

• Both should go together, every time.

It’s time the law reflected that.

Because our kids deserve plans that are based on understanding — not guesswork. 💚

Want to Understand More About Challenging Behavior?

If you want to dig deeper into why kids behave the way they do — and how to respond with connection instead of control — I highly recommend the book:

📘 The Challenging Child by Stanley Greenspan, M.D.

It breaks down the emotional and sensory foundations of behavior in a way that makes sense for real parents — not professionals with a stack of data.

Understanding behavior starts with compassion.

And compassion starts with listening.

References

1. U.S. Department of Education. (2016). OSEP Guidance on Functional Behavioral Assessments and Positive Behavioral Supports.

2. IDEA §300.324(a)(2)(i) — Consideration of Special Factors (Behavior Interference Clause).

3. Council for Exceptional Children. (2020). Best Practices for Behavior Interventions in Schools.

4. Greenspan, S. (1995). The Challenging Child: Understanding, Raising, and Enjoying the Five “Difficult” Types of Children.

© Jackson’s Advocacy — Empowering families to connect, advocate, and grow together.

www.jacksonsadvocacy.com