Transcript Recent Legal Decisions Related to Functional Behavioral Assessment

Recent Legal Decisions Related to
Functional Behavioral Assessment
(FBA)
Heidi von Ravensberg, J.D. ([email protected])
Tary Tobin, Ph.D. ([email protected])
University of Oregon
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Use of functional behavioral
assessments in ways that help prevent
and avoid legal troubles
• Review of Recent Legal Decisions on FBA
• Review of Recent Advances in Use of FBA as
Reported in Education/Psychology Journals
• Comparison of Results from the Searches
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Focus on:
• Factors related to schools being drawn into
lawsuits
• Characteristics of cases won (and lost)
• Distinctions between "best practice" and legal
requirements
• Tips on Preventing Lawsuits
• Practices, Records, and Other Evidence to
Defend Against a Lawsuit
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We wanted to see what federal courts
were saying about FBA with respect to:
• Identifying students’ disabilities and related
special education needs -- as indicated in the
Individuals with Disabilities Education
Act (IDEA)
• Whether an FBA was conducted
• Outcomes on the FBA rulings
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Federal legal decisions in lawsuits
related to functional behavioral
assessments
• Used the Westlaw "all federal cases" database
• From 8/13/2011-8/13/2013
• Search: "functional behavioral assessment" or
FBA and IDEA
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Most cases arose in NY with 12 other
states represented: AL, AZ, DE, IL, IN,
KS, MA, ME, MO, PA, RI, TX
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Results
• 27 cases dropped for not meeting criteria
• 30 cases are U.S. District Court
• 7 cases are U.S. Circuit Court of Appeals:
2nd Cir (NY, 3)
3rd Cir. (PA, 1)
5th Cir. (TX, 2)
8th Cir. (NE, 1)
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Inclusion/Exclusion Criteria:
• Decision must contain a ruling on an FBA issue
• The ruling on the FBA was the final
adjudication
• Did not include New York because it has
unusual state regulations for FBA compared to
federal regulations and other states.
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Diagnoses/Classifications
• Autism – most common
• Attention Deficit Hyperactivity Disorder
(ADHD)
• Emotionally Disturbed (ED)
• Down Syndrome
• Many had multiple disabilities
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8 factors related to schools being
drawn into lawsuits
1. Student has autism and/or multiple
disabilities
2. Student has deficits in communication, social
skills and/or academics
3. Student’s problem behavior is ongoing,
unresolved and interferes with academics or
others
4. Parent disputes school’s disability diagnoses
and/or classification(s)
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5. Parent and school dispute best way to meet
student’s needs
6. Parent perceives child not making academic
progress
7. School does not conduct an FBA
8. The FBA conducted did not stop the problem
behavior or lead to better grades
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Characteristics and Examples of Cases
Won (and Lost)
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For Ruling in Favor of Parent
• School did not conduct an FBA
• Student’s interfering behaviors went
unresolved despite efforts of school
• Student’s grades suffered
• Parent wanted an FBA
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Examples of Cases with Ruling in
Favor of Parent
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Case Highlights
No FBA Conducted / Outcome in Favor of Parents
Bd. of Ed. of Evanston-Skokie Community Consol. Sch. Dist. 65 v. Risen, 2013 WL
3224439 (N.D. Ill.) (U.S. Dist. Ct. Ill., 2013):
Male, 9-year-old, 2nd grader, Born prematurely; mild delays in articulation abilities;
gross motor delays; educational delays in socialization, play, and self-care
Issue: Dispute focused on the scope of information that school district should consider
in assessing child's behavior.
School’s Position: Instead of considering reports based on student’s behavior at prior
schools, it intended to wait and observe his behavior once he was in its classroom.
Held: Contrary to the School District's argument, there was ample pre-existing evidence
that student’s behavior would impede his learning or the learning of others. Therefore,
the School District failed to perform a proper FBA when it concluded in its IEP that
student’s behavior did not impede his learning or the learning of others, despite his long
history of behavior problems at other schools.
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No FBA Conducted / Outcome in Favor of Parents
Coleman v. Pottstown Sch. Dist., 2012 WL 568707 (E.D. Pa., Feb. 22, 2012) (U.S. Dist. Ct.,
Pa., 2012): Male, 18-year-old, LD from TBI; at age 8 was hit in the head with a lead pipe
Parent’s Position: The Court should consider certain records because they are relevant and
were previously unavailable to parents. Parents said records showed student had significant
deficiencies and emotional difficulties that tend to show that the school district erroneously
failed to conduct an FBA, train school personnel, and provide sufficient psychological
therapy and counseling services.
Held: Granted parents right to supplement the record with the school district’s behavior and
discipline records. They provided information that student was generally off task, engaged
in excessive talking, interrupted teachers, had attention issues, refused to do work, was
disruptive and disrespectful to teachers, slept in class, and refused to cooperate. Despite
school district’s insistence that these records were irrelevant, parents didn’t have access to
them before the hearing, nor could they refer to them during their testimony because they
did not have personal knowledge of all of the behaviors occurring at school as opposed to at
home. Furthermore, even though the school district insisted that the Hearing Officer was
well aware that the Student engaged in all of these behaviors, it appears that the
documentation of the types of behaviors student was engaging in at school went beyond the
types of behaviors discussed in the hearing.
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For Ruling in Favor of School
• FBA was conducted
• Student’s interfering behaviors diminished or
changed
• Student made some academic progress
• FBA was documented
• FBA was basis of the Behavior Support Plan (BSP)
• BSP was included in Individualized Education
Program (IEP)
• IEP identified interfering behaviors and gave
strategies to address them
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Examples of Cases with Ruling in
Favor of School
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Federal Case Highlights
FBA Conducted / Outcome in Favor of School Districts
R.C. v. Keller Indep. Sch. Dist., (U.S. Dist. Ct., Tex. 2013):
Male, repeated 11th grade
History of multiple diagnoses; ongoing dispute if ED or Asperger's
Issue:
Whether student’s IEP was appropriately individualized for him where parents disagreed
with the conclusions of the “IEP team,” some of the content of the IEPs, or the eligibility
category.
Held: Yes. During the 5 years student attended school district, he had a number of
evaluations performed, or funded, by district including Formal FBA. All evaluations
employed various assessment tools and gathered information from variety of sources
including student, his parents, teachers, evaluators, physicians, and psychologists, and
tests that were conducted were recognized as valid and appropriate for evaluating
student's disabilities and were performed by qualified personnel and according to
instructions provided by tests’ creators. R.C. v. Keller Indep. School Dist., 2013 WL
3963985 (N.D. Tex., July 31, 2013).
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FBA Conducted / Outcome in Favor of School Districts
H.D. v. Central Bucks Sch. Dist. (U.S. Dist. Ct., Pa. 2012):
Male, 4th grade
ADHD
Issue: Whether, among other things, school district’s FBA denied student FAPE.
Held: No. Student's IEP offered FAPE. The District made extraordinary efforts to shape
an education program to allow student to progress in both his academic and behavioral
performance.
Revisions to his IEP were made to reflect the observations and data showing which
interventions were and were not succeeding, with unsuccessful interventions and supports
removed and successful ones retained. An FBA by a board certified associate behavioral
analyst was conducted and incorporated into the IEPs. Although these revisions led to
academic progress, the various behavioral interventions reasonably available were not
producing lasting improvement in student’s serious behavior problems or assisting him in
developing appropriate social skills. The IEP's SDI, behavior plan, and placement of
student in itinerant emotional support provided a reasonable next step in maintaining his
academic progress. HD v. Central Bucks School Dist., 902 F.Supp.2d 614 (E.D. Pa., Sept.
28, 2012).
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Recent “Best Practice” Use of FBA
as Reported in
Education/Psychology Journals
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First, what is FBA?
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• “Functional behavioral assessment is a
process of identifying specific environmental
factors that have an influence on when a
particular behavior will occur. . . .used to plan
positive ways to prevent or manage behavior
problems” (Tobin, 2005, p. 3,
http://pages.uoregon.edu/ttobin/Tobin-par-3.pdf).
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Different Ways of Doing FBA
• Experimental: Functional Analysis
• Experimenter compares rates of problem
behavior when followed by different types of
reinforcers, such as attention, tangible,
escape, or automatic (Iwata, Dorsey, Slifer,
Bauman, & Richman, 1982, 1994)
• May produce false positives if not based on
reinforcers from natural environment (Rooker,
Iwata, Harper, Fahmie, & Camp, 2011)
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• Descriptive: “In most educational settings,
information for FBAs is gathered using . . .
interviews with parents, teachers, and
children . . . and observation worksheets that
reflect a running narrative of antecedents,
behaviors and consequences (ABCs) (Bijou et
al. 1968) in natural settings” (Alter, Conroy,
Mancil, & Haydon, 2008, p.201).
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Emphasis on Teacher Training /
Teachers Involved
• Importance of teacher training (Bambara, Goh,
Kern, & Caskie, 2012; Debnam, Pas & Bradshaw,
2012; Duncan, Dufreme, Sterling, & Tingstrom,
2013; Kunnavatana, Bloom, Samaha, & Dayton,
2013; Massé, Couture, Levesque, & Bigén, 2013;
Pence, St. Peter, & Giles, 2014; Stoiber &
Gettinger, 2011)
• Gardner, Spencer, Boelter, DuBard, & Jennett
(2012) found “sufficient evidence to support the
involvement of teachers and parents in the BFA
[Brief Functional Assessment] procedures” (p.
327).
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• Loman & Horner (2014) trained school
professionals other than teachers (e.g.,
counselors, administrators, specialists) to
conduct a basic FBA using a manual that is
available online:
• http://pbis.org/common/pbisresources/public
ations/TrainerManual.pdf
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• Goh & Bambara (2012): “Team decision
making during intervention planning yielded
statistically significantly larger effect sizes
when compared to intervention studies where
team decision making was absent during
intervention planning” (p. 280).
• Reports of specific cases detailing the use of
FBA to plan and implement successful BSP, for
example:
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• Janney, Umbreit, Ferro, Liaupsin, & Lane
(2013) found that “a function-matched
extinction procedure is a critical component in
function-based intervention” (p. 120). In this
study, extinction included reducing teacher
attention to disruptive behavior.
• Materials used included: Functional Assessment and
Motivation Interview/Questionnaire (Janney, 2008),
Function Matrix (Umbreit, Ferro, Liaupsin, & Lane,
2007), and Decision Model (Umbreit et al., 2007).
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• Reeves, L. M., Umbreit, J., Ferro, J. B., &
Liaupsin, C. J. (2013). Function-based
intervention to support the inclusion of
students with autism. Education and Training
in Autism and Developmental Disabilities, 48,
379-391.
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Whitford, Liaupsin, Umbreit, & Ferro (2013)
• High school student with learning disabilities and
ADHD
• Problem behavior in 3 classrooms addressed!
• Team included parent, 3 general education teachers,
special education teacher, and researcher.
• A comprehensive intervention included changes in
teachers’ behaviors -- increased use of praise, escapeextinction, and:
• “Evan’s teachers agreed to walk amongst the students
during instructional periods and student independent
work time to ensure that all students, including Evan,
remained on-task” (p. 157).
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Catagnus, R. M., & Hantula, D. A.
(2011). The Virtual Individual
Education Plan (IEP) Team:
Using online collaboration to
develop a behavior intervention
plan. International Journal of eCollaboration, 7(1), 30-46.
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ISIS-SWIS
A decision system for students
requiring more intensive and
individualized supports for
academic, social, or mental
health services.
Student File
Guiding Questions
• Are we
implementing Carly’s
plan?
• What data,
measures, and
documents do we
have readily
available?
• Who are the
members of Carly’s
team?
• What questions do
we have regarding
the progress of the
plan?
• What data might we
look at next?
Report Type: Measure Guiding
Questions
• How is the student
performing in
relation to the
outcome goal?
• What are the
trends, peaks and
patterns?
• What are the next
steps?
• How do these
data compare to
fidelity and other
outcome data?
A Comparison of the Legal and
Education/Psychology Study
Results
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Distinctions between "best practice"
and legal requirements
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Federal IDEA Legal Requirements
• Fail to explain the purpose of the FBA
• Fail to define FBA
• Fail to provide a standard for how schools are to
conduct FBAs
• Fails to say FBA is foundational to a BSP
• School must conduct FBA for certain disciplinary
removals
• School must provide PBIS but FBA not specifically
mentioned
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Best Practices
• Properly identify students’ disabilities and
needs
• Conduct FBA when student’s behaviors put
him/her at risk for poor academic
performance or discipline
• Document, document, document!
• Make use of current standards and practices
as provided by the PBIS Center www.pbis.org
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Helpful Practices, Records, and Other
Evidence to Prevent or Defend Against
a Lawsuit
• Use the Individual Student Information System
(ISIS) and the School Wide Information System
(SWIS) to document (see www.pbisapps.org)
• Get information about ISIS/SWIS ready, certified,
etc. at www.pbisapps.org
• Listen to the ISIS/SWIS videos at
https://www.pbisapps.org/Resources/Pages/ISISSWIS-Introduction.aspx
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Summary
• Lawsuits in which FBA was an issue often
involved students with autism, ADHD, and/or
multiple disabilities – and problems in school.
• If school has records showing it used an FBA
as the basis for a Behavior Support Plan, the
outcome of a lawsuit is likely to be in favor of
the school.
• “Best Practice” FBAs may reduce problem
behaviors and prevent lawsuits.
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COMMENTS? QUESTIONS?
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“Best Practices” in Functional Behavioral Assessment (FBA):
Recommended Reading
Alter, P. J., Conroy, M. A., Mancil, G. R., & Haydon, T. (2008). A comparison of functional
behavior assessment methodologies with young children: Descriptive methods and
functional analysis. Journal of Behavioral Education, 17, 200-219.
Bambara, L. M., Goh, A., Kern, L., & Caskie, G. (2012). Perceived barriers and enablers to
implementing individualized positive behavior interventions and supports in school
settings. Journal of Positive Behavior Interventions, 14, 228-240.
Bijou, S. W., Peterson, R. F., Ault, M. H. (1968). A method to integrate descriptive and
experimental field studies at the level of data and empirical concepts. Journal of
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Borgmeier, C., & Horner, R. H. (2006). An evaluation of the predictive validity of
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Catagnus, R. M., & Hantula, D. A. (2011). The Virtual Individual Education Plan (IEP)
Team: Using online collaboration to develop a behavior intervention plan.
International Journal of e-Collaboration, 7(1), 30-46.
Debnam, K. J., Pas, E. T., & Bradshaw, C. P. (2012). Secondary and tertiary support
systems in schools implementing school-wide positive behavioral interventions and
supports: A preliminary descriptive analysis. Journal of Positive Behavior
Interventions, 14, 142-152.
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Dunlap, G., Iovannone, R., Kincaid, D., Wilson, K., Christiansen, K., Strain, P., & English,
C. (2010). Prevent Teach Reinforce--The school-based model of individualized positive
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Hanley, G. P., Iwata, B. A., & McCord, B. E. (2003). Functional analysis of problem
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