In an era where education must rise to meet the needs of all learners, the recently released guidance titled “Using Functional Behavioral Assessments to Create Supportive Learning Environments” (November 2024) fails to reflect approaches grounded in trauma-sensitive care, neuroscience, and neurodiversity-affirming practices. The guidance reinforces outdated frameworks that prioritize managing behavior over fostering safety, connection, and authentic growth. This critique outlines critical concerns with the guidance and proposes a more supportive and research-aligned path forward.

Reductionist Framing of Behavioral Functions: 

The guidance heavily emphasizes the idea that behaviors serve functions such as “seeking attention” or “avoiding tasks,” but this framework oversimplifies human motivation. Decades of research on human needs, from Maslow to self-determination theory, emphasize that individuals are motivated by deeper, more fundamental needs of connection, safety, autonomy, competence, and belonging (Maslow, 1943; Deci & Ryan, 1985; Ryan & Deci, 2000; Baumeister & Leary, 1995). More recent studies have expanded these concepts in educational settings, showing that students’ motivation and well-being are strongly influenced by the fulfillment of these needs, including autonomy (Patall et al., 2008), competence (Vansteenkiste et al., 2004), relatedness (Juvonen & Graham, 2014), and belonging (Walton & Cohen, 2007), as well as the perception of safety and emotional support (Roeser & Eccles, 2000).

The focus on behavioral functions rooted in obtaining or avoiding something trivializes students’ lived experiences and disregards their intrinsic motivations. For example, labeling a student’s behavior as “attention-seeking” ignores that the behavior might actually be an attempt to meet a critical need for connection or safety. Functional assessments that rely solely on surface-level observations fail to account for broader contextual influences on behavior (Gable, 1996). Describing a behavior as “task avoidance” fails to consider how fear of failure, lack of relevance, or unmet physiological needs might drive the behavior (Deci & Ryan, 1985; Maslow, 1943).

Effective support should move beyond assigning reductive labels to behaviors and instead address the underlying unmet needs that motivate them. Rather than framing behavior as an attempt to “get” or “avoid” something, behavioral support should be grounded in the understanding that all behaviors are adaptive attempts to meet fundamental needs. This requires educators to look beyond the behavior and recognize that behaviors are surface-level expressions of deeper struggles, such as feeling unsafe, disconnected, or overwhelmed. 

Instead of asking, “What does the student want?” or “What are they trying to avoid?” educators should ask:

• “What need is this behavior communicating?”
• “How might past experiences influence behavior?” 
• “How can we reduce perceived threats and foster felt safety?”

Behaviors like task avoidance may signal anxiety, sensory overload, or unmet physiological needs—not intentional noncompliance. Functional Behavioral Assessments (FBAs) must go beyond identifying antecedents and consequences to explore the root causes driving patterns of dysregulation.

By relying on behaviorist principles that reduce student actions to simplistic functions, the guidance perpetuates a transactional view of behavior. This approach assumes students act out of a desire to manipulate their environment for rewards or escape—an oversimplification that ignores the inherent complexity of human motivation (Gable, 1996).

Maslow and other humanistic theorists have long emphasized that individuals are driven by a hierarchy of needs, with safety, belonging, and self-esteem being foundational (Maslow, 1943; Baumeister & Leary, 1995; Ryan & Deci, 2000). Ignoring these deeper motivators risks reinforcing environments that fail to meet students where they are.

Lack of Trauma-Sensitive and Relationship-Driven Approaches:  

The guidance superficially acknowledges trauma but fails to embed trauma-sensitive principles, such as how adult nervous system states influence student regulation. Without this, the guidance misses a foundational component of trauma-sensitive practices.

Trauma-sensitive approaches require behavioral assessments to:

• Recognize that past trauma, neurodivergence, individual differences, and lived experiences impact behavior. 
• Recognize the impact of adults’ nervous system states on students’ stress responses.
• Assess how staff responses (tone, body language, interactions) escalate or de-escalate a student’s stress response.
• Gather data to evaluate the effects of staff responses on escalating or de-escalating stress responses.
• Observe co-regulation practices which help stabilize students’ autonomic nervous systems through relational connection.

Functional Behavioral Assessments (FBAs), as presented in the guidance, fail to consider these relational and systemic factors, focusing narrowly on student behavior without gathering comprehensive information to help teams understand why it emerges in the first place.

Failure to Incorporate Neuroscience and Stress Response Frameworks: 

The guidance disregards neuroscience research on stress responses and the nervous system’s role in behavior (Delahooke, 2019). It overlooks concepts like neuroception—how individuals detect safety or danger and how the autonomic nervous system (ANS) drives stress responses through fight, flight, or freeze pathways (Porges, 1995). Behaviors often emerge as subconscious, protective responses to perceived threats (Doan et al., 2019)—not deliberate attempts to gain or avoid something.

FBAs must go deeper to include:

• Shifting focus from isolated behaviors to clusters of behaviors linked to underlying stressors.
• Identifying the wave of distress—how students progress through stress responses, from early signs of unease to escalation and recovery—to align supports with each phase of this progression (Persike, 2024).
• Supporting educators in recognizing their students’ early signs of distress (Kolacz et al., 2019).
• Identifying stressors—factors that shrink the student’s window of tolerance—and triggers—predictable cues that activate stress responses in our students (Siegel, 2010).
• Recognizing how subconscious stress pathways (fight, flight, freeze) manifest in behaviors like withdrawal, shutdown, or elopement (Delahooke, 2019).

For example, a student avoiding tasks may not be exhibiting defiance but signaling overwhelm, fear of failure, or sensory overload. The FBA process must include these deeper root causes, not just observable antecedents and consequences.

Additionally, the guidance perpetuates the misconception that a single “behavior of concern” can or should be addressed in isolation. In reality:

• Behaviors often occur in patterns or clusters that reflect deeper needs or stress responses (Persike, 2024).
• Addressing one behavior without understanding its connection to others is reductive and unlikely to create lasting change.

For example, a student might engage in task avoidance, sensitivity to demands, and disrupt peers’ learning simultaneously. Each behavior may stem from a shared root cause, such as anxiety, sensory overload, or feelings of overwhelm. The focus should not be on eliminating specific behaviors but on understanding the underlying factors driving the overall pattern of behaviors that occur in the predictable wave of distress that students—and all humans—experience during stress responses. This is a critical omission of understanding the wave of distress is foundational to effective behavior support. 

Lack of Neurodiversity-Affirming Practices:  

Current educational practices increasingly recognize and honor the variability in brain wiring among students. However, this guidance is rooted in deficit-based language and practices, such as a focus on “fixing” behaviors without celebrating the strengths of neurodivergent learners. 

The guidance’s focus on behavior “functions” (e.g., seeking attention, avoiding tasks) perpetuates a deficit-based view of neurodivergent students. Effective support for neurodivergent students involves fostering environments that adapt to their needs, celebrate their strengths, and welcome their differences rather than coercing compliance and conforming to societal norms (Singer, 1999; Armstrong, 2010).

To align with neurodiversity-affirming practices, FBAs should:

• Avoid framing behaviors as problems to “fix” or “replace.”
• Evaluate sensory needs, stressors, and environmental conditions that impact regulation.
• Recognize behaviors like stimming as adaptive and supportive for self-regulation.
• Gather information regarding the student’s neuroinclusive needs. 

The guidance largely positions behavior as something inherent to the student, neglecting the significant role of systemic and environmental factors. For instance, the emphasis on antecedents, behaviors, and consequences (ABC) in Functional Behavioral Assessments (FBAs) frames behavior in isolation, without adequately addressing how classroom conditions, educator responses, or school policies contribute to dysregulation. This narrow focus risks blaming students rather than fostering systemic accountability.

Insufficient Evaluation of Environmental Influences

While traditional FBAs do consider aspects of the environment through antecedent analysis, this approach often focuses narrowly on immediate triggers without examining broader environmental factors that shape behavior over time. This limited scope reinforces a deficit-based perspective, placing the responsibility for change primarily on the student rather than addressing the classroom conditions and expectations that may contribute to dysregulation.

Stress is cumulative, and small stressors can build upon each other, gradually shrinking a student’s window of tolerance. Additionally, research shows that memories are stored as sensory experiences with emotional tags, meaning that sensory triggers can evoke powerful emotional responses, whether calming or distressing (Delahooke, 2019). These responses are often subconscious, driven by past sensory experiences that have been emotionally encoded, and they can activate the fight, flight, or freeze response. A thorough evaluation must account for how these sensory and emotional associations shape students’ ability to regulate in different environments.

A comprehensive assessment must consider factors such as:

• Noise levels, lighting, visual clutter, and other sensory elements can overwhelm or calm students. Autistic students often experience heightened sensory processing, with studies showing they have four times the neurons related to sensory input (Casanova et al., 2006). Understanding sensory preferences and reactivity is essential for creating supportive environments that reduce masking, withdrawal, or overwhelm, while minimizing triggers for stress responses. 
• Classroom expectations should meet the diverse needs of all learners and avoid unintentionally causing masking, withdrawal, overwhelm, or a lack of belonging. For example, expectations like “eyes on me” or “criss-cross applesauce,” while well-intentioned, may place undue stress on students who process and regulate differently.
• The degree to which routines, transitions, and academic demands are adaptable to individual differences in sensory processing, energy levels, and emotional needs.

By focusing narrowly on isolated antecedents, traditional FBAs may miss these broader environmental influences. Effective assessments should evaluate whether classroom environments and expectations foster regulation, connection, and belonging—or create unnecessary stress and disengagement.

Expanding the scope of environmental analysis helps uncover the root causes of behavior by examining how sensory inputs, classroom expectations, and environmental factors contribute to dysregulation. Understanding the deeper “whys” behind behavior allows educators to move beyond surface-level observations and develop targeted, meaningful supports.

Missing Opportunities for Meaningful Collaboration 

The guidance falls short of offering actionable steps, templates, or examples for implementing FBAs in ways that are trauma-sensitive, neurodiversity-affirming, and collaborative. A meaningful approach to behavioral support must include practical tools for educators and foster shared ownership among students, families, and school teams.

Effective evaluations require collaboration with families and students because they hold valuable insights into the student’s history, strengths, needs, stressors and triggers. Without their voices, assessments risk being incomplete and biased, relying solely on adult observations in limited contexts.  The guidance briefly mentions involving parents and students but does not describe how to include them meaningfully. There is no mention of tools or strategies for educators to gather insights from parents about their child’s experiences or to create space for students to express their needs, preferences, and challenges. This omission reinforces a top-down approach to behavior that undermines the shared ownership and trust necessary for lasting change.

The guidance’s emphasis on “replacement behaviors” not only places the burden of change on the student but also excludes them—and their families—from meaningful participation in determining their own goals. Growth should be a collaborative process that prioritizes the student’s voice, their family’s insights, and their unique strengths and challenges.

By dictating what behaviors need to change, educators risk stripping students of agency and perpetuating the harmful notion that their differences are problems to be fixed. Instead, we should ask students and families where they see opportunities for growth. Every individual has areas they wish to develop, and honoring this process reinforces the idea that growth is a shared and empowering experience, not a compliance exercise.

Failure to Address Holistic and Relational Needs

The guidance misses a critical opportunity to evaluate holistic health and relational factors within FBAs. Traditional assessments often rely too heavily on observable, surface-level behaviors without considering the holistic and environmental factors that shape them (Gable, 1996). A comprehensive assessment must include:

• Holistic influences, such as sleep (Persike, 2024), health, and exercise, which play a direct role in behavior (Roeser & Eccles, 2000).
• The quality and depth of relationships within the environment and their impact on regulation (Baumeister & Leary, 1995; Kolacz et al., 2019).

No Emphasis on Escalation, De-escalation, or Repair

The omission of escalation, de-escalation, and repair is one of the most significant faults in the guidance. By focusing narrowly on behavior change, it ignores the relational, emotional, and systemic aspects of these episodes that are essential for creating lasting, meaningful support.  Instead, it focuses heavily on behavior modification—changing the student’s behavior—without addressing how to support both students and staff during moments of distress. This oversight leaves educators without guidance for managing some of the most challenging and high-stakes situations they face. A truly comprehensive assessment must:

• Map out early signs of distress, like increased movement or physical agitation, to inform timely supports. 
• Describe how a student looks as they move from regulation to distress and de-escalation. 
• Provide adequate baseline data regarding frequency, intensity, and duration in order to adequately monitor change and progress over time.

What We Need Instead

To align with trauma-sensitive, neuroscience-based, and neurodiversity-affirming practices, FBAs must:

• Evaluate stress responses through a neurobiological lens rather than reducing behaviors to “functions.”
• Evaluate how staff interactions and the learning environment impact students’ regulation and stress responses.
• Map the student’s wave of distress to understand behavior progression and tailor supports to each phase.
• Recognize behaviors as adaptive and focus on reducing stressors, not controlling outcomes.
• Involve students and families as collaborative partners to ensure assessments reflect their lived experiences, perspectives, and needs.

By shifting FBAs to focus on felt safety, connection, and regulation, we move away from punitive, compliance-driven frameworks toward approaches that honor students’ humanity and unique neurobiological needs.

Are We Truly Listening?

This guidance reflects a missed opportunity to align our practices with what we now know about the brain, the nervous system, and the critical role of safety and connection in learning. Traditional FBAs, rooted in nearly century-old behaviorism, reflect an antiquated framework that reduces students to their behaviors rather than honoring their humanity. Ignoring neuroscience (Porges, 1995), trauma-sensitive practices (Kolacz et al., 2019; Armstrong, 2018), and lived experiences (EUCAP, 2024; ASAN, 2016; Autistic Collaboration Trust, 2022) not only undermines effective support but risks perpetuating harm.

But this isn’t just about research or theories. It’s about people—those who have lived through systems shaped by these outdated beliefs. If we were truly listening to their voices, we would hear their overwhelming rejection of these practices. We would hear their stories of harm, of trauma, and of being misunderstood in ways that still echo in their lives today. They have been courageous enough to come forward and tell us what needs to change (EUCAP, 2024; ASAN, 2016; Autistic Collaboration Trust, 2022). The question is: Are we courageous enough to listen?

This is not to say that assessment and planning are inherently bad—far from it. A good assessment can be transformative, uncovering the root causes of a child’s struggles and creating a path forward that truly supports the student, the family, and the entire team. A thoughtful plan, one rooted in understanding and collaboration, has the power to bring relief and progress. 

Surface-level assessments and plans, however, do not help anyone (Gable, 1996). They only lead to frustrated teachers, students with low self-worth and unmet needs, families who feel unheard and traumatized, and cycles of harm that ripple through lives.

We owe it to every child, every educator, and every family to do better. To continue accepting frameworks that perpetuate harm—whether intentionally or through inaction—is to dismiss the lived experiences of countless individuals who are calling for change. We cannot claim to support students while upholding practices that deny their autonomy, pathologize their differences, and undermine their dignity. If we are serious about creating systems that truly serve, we must challenge ourselves to learn, to listen, and to do better.

The tools, knowledge, and voices are here. The choice is ours: Do we continue doing what we’ve always done, or do we embrace the chance to create something better—something that reflects the humanity of every student, educator, and family involved?

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