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Topic of the Day

How I.D.E.A. Increases the Need for 
Functional Behavior Analytic
Skills in Public Schools: 
What they don't know can hurt us!

Initially read at:
25th Annual Convention of
The Association for Behavior Analysis
May 1999, Chicago

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 efficiently. 

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 us!"

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 schools.

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 University, was:

"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 programs."

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) that:

"IDEA '97's requirements for "functional assessments of behavior continue to arouse anxiety and confusion among school psychologists."

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." (Dwyer, 1998) 

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 that:

"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, 1998).

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 at: http://www.connective.com/events/deptedu/IDEA/ideatranscript31899.html

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). Or: http://www.naspweb.org/services/cq/cq275fba1.htm

Thomas, A. (1997, November). "Functional Assessment" - Not something new. NASP Communique, 26(3). Or: http://www.naspweb.org/services/cq/f%2Da.html


Dr. Montgomery is available to consult to you, on both specific service needs and as a  reviewer of professional credentials and qualifications in the field of behavior analysis, ABA, Functional Behavioral Assessment/Analysis, and clinical psychology generally.

tips.gif (506 bytes)  Today's Resource Tip:

The Association for Behavior Analysis International  is the premier professional organization for those adhering to the functional approach to behavior change.  ABA publishes these peer-reviewed journals: The Behavior Analyst, JABA, JEAB, and The Analysis of Verbal Behavior.  ABA also has a number of affiliated state chapters.  ABA's annual meeting is always full of material on the range of behavioral strategies for effecting efficient change.  Advanced technical information on Functional Behavioral Assessments is always featured at the annual meeting.  The annual convention is held in late May. Questions can be sent to Dr. Montgomery at .


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