While it is true that as Forsyth, Kollins, and
Canna have pointed out all too many of our colleagues in Behavior Therapy are
not using functional-analytic approaches to assessment, many advances in
behavioral assessment have been made over the past 30 years - not the least of
which is the recent emphasis on Functional Behavior Assessment. Many of the
other talks given at ABA this year have focused on technical and scientific
issues relating to the refinement of the process of conducting and utilizing a
Functional Behavior Assessment. Each such presentation or paper advances the
technology - its precision and its applicability to a wider range of
questions. These advances improve our ability to use intervention strategies
with increased accuracy and effect changes in behavior more rapidly and
The single largest impact on the use of Functional Behavior Assessment has
nothing to do with these advances in our technology. The single largest factor
in the utilization of Functional Behavior Assessment has nothing to do with
our science or degree of scientific rigor. While these factors are at the
center of many talks here at the annual conference and papers in our journals
they have little to do with the uses to which FBAs are being put or who is
deciding the "W" questions relating to FBAs - the Who does them, the
When they are done, the Why they are done, and What impact the findings have
on programming. The single largest factor in the utilization of Functional
Behavior Assessment is all about regulations and politics and that is what
this talk is about today.
A series of public laws - Federal Laws - have had the greatest impact on
the utilization of Functional Behavior Assessments.
First, Public Law 94-142 mandates that every child in the United States is
entitled to a Free and Appropriate Public Education (FAPE) which means that
the public schools in the U.S. are the only government agencies obligated by
Federal Law to serve every child regardless of their resources, ability to
pay, or severity of disability or behavior. With the introduction of
"Managed Care" into all aspects of service delivery - INCLUDING
government-based services - there has come a decrease in services available.
These decreases have been felt nowhere more severely than in Child &
Adolescent services both public and private. Now, you may ask yourself -
"What does this have to do with FBA?" ......
The answer is that public schools in the U.S. are serving more disabled
students and increasingly students with more serious behavior needs. In the
Metro-Atlanta area it is not uncommon for 20-25% of enrolled students to have
a special education label through either an IEP or a 504 plan.
Other public agencies know that the schools are unable to decline to
provide services and so are "allowing" schools to bare the brunt of
such service delivery with greater regularity. In Georgia, as an example, the
State Mental Health Agency "redirected" over 65% of its Child and
Adolescent service delivery budget over the past 5 years. Inpatient options
are quickly fading as realistic and this means that students with problems
seldom if ever seen in schools 30 - 20 - and even 10 years ago are routinely
being seen in public schools today.
The Second piece of Federal Legislation that you add to this increased
demand for services is the Individuals with Disabilities Education Act of 1997
- I.D.E.A. '97.
I.D.E.A. '97 was signed into law on June 4th 1997 and U.S.
Department of Education regulations governing how the law is to be implemented
were finally promulgated in March of this year (1999) and went into effect
this month (May, 1999). I.D.E.A. '97 and the Department of Education's
regulations govern how individuals with disabilities within public schools are
to be served and includes specific language within various sections - most
notably the discipline section (615(k)) requiring the use of "Functional
Behavior Assessments". IDEA '97 requires that a FBA be conducted that
leads to appropriate behavior interventions when suspension exceeds 10 days, a
change in placement is being considered because of "disciplinary"
issues, or if a special education student is placed into an "interim
45-day alternative setting". The regulations and law further require that
the FBA be conducted within 10 days of any of these actions.
The combination of the law which specifically mandates Functional
Behavioral Assessments under a variety of circumstances and the increased
demand for "special" services within the schools is a very important
and powerful set of circumstances that we as behavior analysts need to be more
aware of and involved in. Essentially, the federal government has increased
the potential market for ABA services immensely.
Robert Horner at the University of Oregon has not only been involved in
practical application issues related to FBAs but has also been a central
consultant to the Dept. of Education during its development of the IDEA
regulations. He recently appeared on a nationally broadcast teleconference in
March (1999) sponsored by the DOE to answer questions regarding IDEA and FBAs
and made the point that FBAs are not psychometrics as usual but rather that at
core they involve a contextual evaluation of a behavior developed via direct
observation of the student within the actual environment in which the
behaviors occur naturally.
So, the DOE in providing guidance for IDEA has essentially endorsed an
understanding of the term "Functional Behavior Assessment" that is
well understood by us here at ABA. In the teleconference, Robert Horner went
through the various components that are included in the O'Neill, Horner et
al. text Functional Assessment and Program Development for Problem Behavior
and the various officials of the DOE Special Education offices present at the
teleconference repeatedly referred questions on what FBAs are, how they are to
be conducted, and what the intent of doing them is to Robert Horner. This
leaves little doubt that a Functional Assessment as required under IDEA is
nothing other than what we as Behavior Analysts generally recognize the term
to mean: the development of an understanding of the relationship between the
EO, Antecedent, Behavior, and Consequences as they relate to a specific child
under certain circumstances. Nothing in the legislation or the regulations as
promulgated by DOE, or their various education and support efforts, would
suggest otherwise. FBA is used within that context in the same manner that it
is used in Journal of Applied Behavior Analysis and our classrooms.
The subtitle of this piece is "What they don't know can hurt
After having spent the past several years doing nothing but consulting to
schools: the central question that leapt to my mind after reading the I.D.E.A.
'97 regulations was "Who is qualified to do all these FBAs now required
of the public schools?"
Let me tell you a little story that might help illustrate why I am
concerned about this new requirement and its application in the public
Recently a school to which I and a colleague consult presented a proposed
behavior management plan to the schools Rights Protection Committee. Now, we
are the ones that convinced the directors of the school that they needed to
have an independent RPC process in addition to a Behavior Peer Review
Committee for the school and view this addition as a very important positive
step for the school. The RPC had two new members on it, both of whom are
professors in education at the local university. The RPC had been provided a
detailed written plan for the proposed program prior to their meeting and then
had a presentation of the underlying problem, the data collected relating to
that problem, and the proposed interventions based on the perceived function
of those behaviors as derived by the direct observation data collection and
experimental manipulations designed to test the hypotheses developed regarding
the functions of the targeted behaviors. The committee listened attentively to
all this, several members thumbing through their printed copy of the proposed
plan while the presentation went on, and then discussion and questions were
called for by the chair. The first, and I might add only, comment from one of
the new members, a Full Professor in Special Education at the local
"Sounds like you need to conduct a Functional Behavior Assessment
before you go making all these intervention proposals to us!"
And just why did he think the two doctoral level behavior analysts had
collected all that data and done those experimental manipulations?
This encounter led me to investigate the state of the field among the front
line "experts" on assessment in public schools - School
Psychologists. First a bit of background, School Psychologists do not have to
be licensed as psychologists but are routinely required to meet The National
Association of School Psychologists (NASP) certification requirements. NASP
represents more than 24,000 school psychologists and related practitioners who
are required to have a minimum of 60 graduate semester hours including a
year-long internship (as of 1999).
That process of investigating this issue was an amazing one which was very
disheartening. Of the 22 NASP certified School Psychologists questioned by me
regarding what an FBA is and what the essential difference between it and
traditional psychometrics is only two could answer the questions adequately as
defined by undergraduate texts in behavior analysis.
The other 20 were unable to differentiate between topography and function,
were unable to state in even the vaguest terms that direct observation lies at
the heart of a FBA, most suggested that FBAs are nothing new, almost all
claimed to have been doing FBAs for years!?!
It seems that the initial reaction by many in the National Association of
School Psychologists and others professional educators was to say that FBA is
1) Narrow, 2) simple, and 3) of little utility. As the legislative process
advanced and FBA remained a part of the legislation NASP appears to have
shifted its ground as evidenced by public statements by various NASP officials
in such outlets as the "NASP Communique" amongst others. In November
1997 after IDEA had been signed into law containing the FBA provisions some on
the NASP Executive Council were arguing that there was little literature on
FBA and that "this was not currently emphasized in training
Alex Thomas (Thomas, 1997),
at that time President-Elect of NASP, responded:
" 'Gimme a break' was [His] response when a number of folk at a
recent NASP honcho gathering (Executive Council) indicated that IDEA (PL
105-17) reauthorization's emphasis on "functional assessment"
would be a challenge to implement for many school psychologists."
Thomas then went on to argue that School Psychology in general and NASP in
particular had argued for "functional assessments" for years.
"Functional assessment is neither a new nor a difficult concept. It is
not a specific procedure but rather a perceptual style. A style that
emphasizes the end product of assessment which is to guide decision making
that aids the academic or behavioral progress of a child."
Kevin P. Dwyer the President-Elect of the National Association of School
Psychologists wrote recently (1998)
"IDEA '97's requirements for "functional assessments of
behavior continue to arouse anxiety and confusion among school
Why would such a requirement "arouse anxiety and confusion among
school psychologists." if they felt they were adequately trained to
conduct these assessments - in fact had been doing so for years - as asserted
by Professor Thomas? Mr. Dwyer answers this question my stating that:
"the revised law requires nothing beyond current school psychology
practice." He then goes on to use a Alice in Wonderland sort of
linguistic maneuver by asserting that:
"All assessments (evaluations) must be "functional" under
the law and this is consistent with NASP policy."
So, ipso facto FBAs are the equivalent of what
school psychologists have been doing for years.
Skiba and colleagues at Indiana University's School Psychology Training
Program argued (Skiba, et al. 1998)
that despite the assertions of Thomas (1997)
and Dwyer (1998)
among others that FBA is "not a new skill for many school psychologists,
and not even a completely new requirement in federal legislation" state
that in fact for school psychologists "the fundamental assumptions of
functional assessment, and the procedures that grow out of those assumptions,
do in fact represent a dramatically new perspective in addressing disruptive
behavior". They go on to point out that functional assessment is a new
PARADIGM for school psychology that allows school psychologists to "move
beyond [their] traditional conceptualizations of assessment of assessment and
better understand the context of the behavior and the function of that
behavior for the child."
Skiba and colleagues hit the nail squarely on the head when they state
"A functional approach moves us away from routinely applying a
generic and often reactive behavior management plan, toward gathering
information that increases our understanding of the student behavior in the
classroom and identifying and teaching needed replacement behavior."
Least you think that these assertions and quotes are somehow aberrant,
dated, or taken in isolation a series of articles in the NASP newsletter (Stewart,
1999) appeared that engaged in rhetorical
assaults on FBA via such strategies as Straw Person, argument from authority,
demonization, and false analogy. In essence the arguments boiled down to two
issues: FBA is reductionistic and non-empathic - the same old arguments that
have been used within the public education establishment for decades to
marginalize empirically supported applied behavior analysis. Mark Steege,
himself a school psychologist and director of the School Psychology program at
the University of Southern Maine, along with Amy Donovan were invited to write
replies to these commentaries in the NASP Communique (Donovan,
1999) earlier this year by its editor.
Specifically, the old anti-behavioral rhetoric was brought to bare within the
NASP newsletter that FBA - by virtue of being behavioral in origin is cold,
unconcerned with the "person" of the child, narrow (Meaning that
ONLY the behavior of the child is considered and not the WHOLE child), not
supported for anything beyond SIB in the developmentally disabled, and
simplistic. Steege (1999)
points to the large and growing literature base on a wide range of behaviors
across populations as well as to the various levels of complexity of FBA from
interviews to extended experimental manipulations. Interestingly, Ms. Donovan
points out that many school psychologists with whom she has worked view FBA as
only "counting behaviors" and counters that "If the only task
of FBA was to count behaviors, it certainly would not have been added to the
1997 IDEA legislation." She then goes on to point out that the
development of a "coherent" contextual understanding of the function
of a behavior (or group of behaviors) involves a lot more than merely
"counting" them as so many of her colleagues assume.
The tactics of some within the "Professional Education" community
has been to dismiss FBA as nothing new and failing that to minimize and
marginalize the process by rhetorical ploys linking it to that old
"evil" behavior modification or to claim, as did the current
President-Elect of NASP that the goal of FBA is to "focus on descriptive,
EASILY understood, observable problem behaviors" (Dwyer,
Am I demonizing professional school psychologists and NASP? No. Many of the
most cogent responses to the myopic views presented within NASP regarding FBA
have been made by members of NASP. Professional educators at the Department of
Education guided the legislative process in developing IDEA '97 which
includes specific language mandating FBAs and have included key behavior
analysts in the process of educating local education agencies on what FBA is
and how to implement these requirements.
What I am saying is that it appears that too many within the education
establishment, including many in elected positions within NASP and practicing
school psychologists, remain anti-behavioral and therefore anti-FBA. They
counter that they are already doing FBAs, even that they have been doing them
for years. Their president-elect even argues that every assessment has to be
"functional" and that therefore every school psychologists
assessment is an FBA.
If such non-FBA processes and recommendations are allowed to go forward
unchallenged as FBAs than true behavior analytic FBA runs the very real risk
of being discarded because it is another failed "improvement" in
service provision by public schools. This perceived failure will not be
because FBAs, when done correctly, is not of genuine utility but rather
because through an Alice-in-Wonderland linguistic move some will have
mislabeled the same old intra-psychically driven assessments as FBAs.
We, as behavior analysts, have an obligation to confront this sort of
chicanery head-on. We also have an unprecedented opportunity to facilitate the
introduction of scientifically sound techniques into the public schools for an
ever growing population of special education students. The mandates of IDEA '97 and the regulations as promulgated by the Department of Education have
opened a rather large door - our job is to make sure that it does not close in
our faces because others who are anti-behaviorists are allowed to define terms
and control training in FBA and other skills.
Donovan, A. L. (1999, February). Viewpoints:
Response to Stewart: FBA extends understanding and positive outcomes. NASP
Communique, 27(5). Or: http://www.naspweb.org/services/cq/cq275fba3.htm
Dwyer, K.P. (1998, February). IDEA '97: Using
functional assessments of behavior. NASP Communique, 26(5). Or: http://www.naspweb.org/services/cq/cq265funcassess.htm
Horner, R. (1999). The U.S. Department of
Education broadcast on ConnectLive.Com News Network "IDEA 97
Regulations" Thursday, March 18, 1999 from 2:00-4:00 pm EST is available
Individuals with Disabilities Education
Act of 1997, Department of Education, Office of Special Education Programs,
Washington, DC. Or: http://www.ed.gov/offices/OSERS/IDEA/regs.html
O'Neill, R.E., Horner, R.H., Albin, R.W.,
Sprague, J.H., Storey, K., & Newton, J.S. (1997). Functional assessment
and program development for problem behavior: A practical handbook (2nd
ed.). Pacific Grove, CA: Brooks/Cole Publishing Co.
Skiba, R., Waldron, N., Bahamonde, C.,
& Michalek, D. (1998). A four-step model of functional behavior
assessment. NASP Communique, 26(7). Or: http://www.naspweb.org/services/cq/cq267fbamod.html
Steege, M.W. (1999). Viewpoints: Response
to Stewart Functional assessment: An odyssey. NASP Communique, 27(5).
Thomas, A. (1997, November). "Functional
Assessment" - Not something new. NASP Communique, 26(3).