Fixing the Mine: Why Functional Behavioral Assessments Miss the Mark on Inclusion
The US Department of Education’s recent guidance on Functional Behavioural Assessments (FBAs) positions itself as a progressive step towards reducing exclusionary discipline in schools. Framed as a way to replace punitive measures with “evidence-based interventions,” it promotes understanding student behaviour through a lens of unmet needs. At first glance, it seems promising, a step in the right direction for fostering inclusion and improving outcomes for students whose behaviour is often misunderstood or pathologised.
However, a closer look reveals that this guidance is rooted in a deficit-based framework. It treats students’ behaviours as problems to be corrected, often without interrogating the environments or situations that shape those behaviours. The focus remains on “fixing” the student rather than addressing systemic and environmental factors that may be contributing to their distress. It’s reminiscent of the old practice of using canaries in coal mines to detect toxic gases. When a canary collapsed, it wasn’t the bird that was broken—it was the environment that was unsafe. Instead of fixing the canary, the miners needed to fix the mine. Similarly, when students struggle, their behaviour often signals an environment that is unresponsive to their needs, yet this guidance largely ignores the role of classrooms and schools in shaping those behaviours.
What’s more, the guidance lacks transparency about the involvement of stakeholders in its development. Whilst it references “listening sessions” with educators, parents, and advocates, it’s unclear how these voices were weighted or whether neurodivergent individuals, who are disproportionately affected by FBAs, were meaningfully included. Furthermore, the absence of neurodivergent-led resources in its recommendations is striking. For guidance that directly impacts autistic students and others with disabilities, this omission underscores a troubling one-sidedness. By focusing on individual behaviours rather than systemic transformation, the guidance misses the opportunity to truly reimagine inclusion in our schools.
A Deficit-Based Framework in Disguise
FBAs are often presented as a cornerstone of “evidence-based practice” in managing classroom behaviour. Their stated purpose is straightforward: to identify the reasons behind behaviours that interfere with learning, using this understanding to develop “targeted interventions.” Rooted in behavioural psychology, FBAs emerged in the late 20th century as a tool for addressing “challenging behaviours” in students with disabilities, particularly within the framework of the Individuals with Disabilities Education Act (IDEA). Over time, their application has expanded beyond special education, with proponents suggesting that FBAs can benefit any student whose behaviour “disrupts the classroom environment.”
On the surface, this may seem like a reasonable approach. Yet the framework on which FBAs rest reveals a deeper problem: their tendency to pathologise behaviours rather than address the environments that provoke them. By reducing behaviour to antecedents, actions, and consequences, FBAs position the student as the source of disruption, effectively shifting focus away from the systemic and environmental factors that may be contributing to their distress. Instead of asking how the classroom might better accommodate diverse needs, the process implicitly assumes that the problem lies within the student, perpetuating a deficit-based perspective that centres conformity as the goal.
This approach often enforces compliance over genuine inclusion. Students who “interfere” with learning are analysed, charted, and redirected, but little thought is given to whether the classroom itself is a supportive space for their unique needs. For neurodivergent students, particularly those who are autistic, FBAs frequently target natural expressions of neurodivergence—stimming, vocalisations, or movements—as behaviours to be extinguished. This risks suppressing not only individual traits but also the right of these students to be themselves within the classroom.
It’s a dynamic akin to blaming the canary for collapsing in a coal mine. The canary’s distress was never about its own failings but about the toxic conditions surrounding it. Similarly, a student’s behaviour is often a signal of unmet needs, an indicator that their environment is not supporting them. FBAs, by focusing on “fixing” the student, fail to address these systemic issues. What if, instead of documenting and analysing the canary’s collapse, we focused on clearing the air in the mine? Genuine inclusion requires recognising and adapting to the needs of all students, not demanding that they conform to rigid norms. FBAs, as they are typically applied, fall short of this goal, perpetuating systems that prioritise control over care.
The Transparency Problem: Who’s Really at the Table?
The US DOE’s guidance on FBAs claims to have been shaped by stakeholder feedback, citing “listening sessions” with parents, educators, administrators, advocates, and researchers. On the surface, this nod to collaboration might appear to bolster the guidance’s credibility. After all, consulting those directly impacted by policy decisions should ensure the outcomes are both practical and inclusive. But the document provides little detail about who these stakeholders were, how their perspectives were weighted, or how their input was integrated into the final recommendations. Without this transparency, it’s difficult to determine whether the guidance genuinely reflects a range of lived experiences or simply reinforces the status quo.
The absence of this information raises important questions. Were neurodivergent individuals, particularly those with direct experience of FBAs, meaningfully consulted? Were the voices of students and families from marginalised communities—those disproportionately subjected to punitive discipline—given appropriate weight? Or were these sessions more performative than transformative, designed to tick the box of “stakeholder involvement” without committing to substantive change?
For neurodivergent individuals, particularly autistic people, FBAs have long been a source of contention. They are often perceived as tools to suppress natural behaviours, enforcing conformity rather than understanding or accommodation. Many in the autistic community view FBAs through a critical lens, seeing them as part of a broader system that prioritises control over support. If their voices were not actively sought or centred during the creation of this guidance, it becomes difficult to see how it could claim to foster genuine inclusion.
Moreover, what influence did marginalised communities have on shaping these recommendations? Students from low-income and racially minoritised backgrounds are disproportionately disciplined in schools, yet their perspectives are often absent from discussions about interventions like FBAs. If the guidance does not reflect their realities or address the systemic inequities they face, it risks perpetuating the very dynamics it seeks to challenge.
Ultimately, without clarity on these points, the guidance risks being dismissed as performative rather than transformative. Stakeholder involvement is not merely a procedural step—it is essential for ensuring buy-in and fostering trust among those most affected by policy changes. If the DOE intends for FBAs to be a tool for inclusion, it must do more than pay lip service to stakeholder engagement. Transparency about who was at the table—and who was not—is not an optional detail; it is a critical element of any framework claiming to address systemic inequities. Without it, this guidance remains an exercise in power dynamics rather than a pathway to meaningful change.
The Missing Neurodivergent Perspective
FBAs are disproportionately applied to autistic students, a fact that underscores their problematic role in education. These assessments, intended to identify the “why” behind behaviours deemed disruptive, often target natural expressions of neurodivergence. Behaviours such as stimming, echolalia, or other forms of self-regulation are frequently labelled as problems to be managed rather than understood. For autistic advocates, this approach is troubling. Instead of recognising these behaviours as integral to how neurodivergent individuals navigate the world, FBAs risk suppressing them in favour of enforcing conformity to neurotypical norms.
Criticism of FBAs from autistic communities is not new. Many advocates have long argued that these assessments are part of a broader system that seeks to normalise autistic students at the expense of their authenticity. Rather than fostering environments that respect and adapt to diverse ways of being, FBAs often serve as tools to “fix” the individual. This framework can be profoundly damaging, sending a message that who the student is fundamentally needs correction—a message no child should ever receive from their educators.
The omission of neurodivergent-led resources in the guidance’s technical assistance section only deepens this concern. If FBAs are to be a part of fostering inclusive learning environments, the perspectives of those most affected by these practices must inform their implementation. Yet the guidance offers no resources or tools developed by neurodivergent individuals or organisations. Groups such as the Autistic Self Advocacy Network (ASAN), which provide critical insights into how schools can better support neurodivergent students, are notably absent. This exclusion perpetuates a one-sided narrative in which autistic voices are silenced, and their needs are interpreted through the lens of external “experts.”
The implications of this gap are significant. By failing to incorporate neurodivergent perspectives, the guidance reinforces the idea that inclusion is something done to autistic students rather than something created with them. It continues to centre the system’s expectations over the student’s experiences, leaving schools ill-equipped to provide the kind of support that respects neurodivergent identities. Without these voices, any attempt at inclusion risks becoming performative—a gesture that changes little for the students it claims to serve. If we are to move beyond this deficit-based framework, neurodivergent leadership must be at the heart of the conversation.
A Better Way Forward: Environmental Audits
If we are to genuinely address behaviours in the classroom, we must begin by reframing the problem. Behaviour is not defiance; it is communication. When a student acts out or disengages, their behaviour often signals an unmet need—a response to something in their environment that is overwhelming, inaccessible, or unresponsive. Yet too often, schools interpret these signals as challenges to authority, requiring correction rather than understanding. Instead of focusing on changing the student, we should be asking: what can we change in their ‘school experience’ to better support them?
This is where the concept of environmental audits offers a transformative alternative to Functional Behavioural Assessments. Unlike FBAs, which focus on analysing the antecedents and consequences of student behaviour, environmental audits evaluate the classroom itself. The goal is not to “fix” the student but to identify and address barriers within the learning environment that may be contributing to behavioural challenges. By shifting the focus to the classroom as a dynamic participant in shaping behaviour, environmental audits promote inclusion and equity for all students.
An environmental audit begins with a simple yet profound question: is this classroom designed to meet the diverse needs of its occupants? To answer this, the audit evaluates factors such as sensory conditions, accessibility, and the predictability of routines. For instance, are the lighting and noise levels conducive to neurodivergent students, or do flickering fluorescent lights and constant background chatter create unnecessary stress? Is the physical space arranged to allow movement and sensory breaks without disruption? Are classroom transitions smooth and routines clear, or do students face chaos and unpredictability that increase anxiety?
These metrics can be adapted to meet the specific needs of a school’s population. A classroom designed with sensory-friendly lighting, flexible seating arrangements, and quiet spaces for regulation is more likely to support neurodivergent students. Accessible materials in multiple formats—visual, auditory, and tactile—ensure that no student is excluded from participation. Consistent routines provide the predictability that many neurodivergent learners rely on to feel secure and engaged.
Beyond physical and sensory considerations, scheduling plays a crucial role in creating supportive environments. For autistic students, whose energy reserves—or “spoons”—are often depleted by the end of the school day, heavy coursework should be prioritised in the morning. Core subjects, which have a direct impact on graduation, are best tackled when students are fresher. Electives, where missing material poses less risk to academic progress, can be scheduled in the afternoon. Counselling staff and teachers must collaborate to design timetables that reflect this understanding, ensuring that students are set up for success rather than frustration.
Environmental audits represent a shift in mindset from compliance to care. Instead of expecting students to adapt to rigid classroom norms, they encourage educators to adapt their spaces to the students they serve. By addressing the systemic factors that contribute to behavioural challenges, environmental audits offer a pathway to genuine inclusion—classrooms where all students feel seen, supported, and valued. It’s time to stop analysing the canary and start fixing the mine.
From Behaviour Plans to Classroom Plans
The traditional approach to managing student behaviour often centres on Behaviour Support Plans (BSPs), which focus on changing the actions of the student. Whilst the intent may be to help students succeed, the underlying message is clear: the student is the problem, and their behaviour must conform. But what if we shifted this perspective entirely? Instead of crafting plans to “fix” the student, we could design Behaviour-Informed Classroom Plans (BICPs) that adapt the environment to meet the needs of all learners. This simple change in focus could transform classrooms from places of compliance to spaces of care and inclusion.
BICPs are not about individualised interventions to manage behaviour; they are about systemic adjustments to make the classroom more supportive for everyone. For example, rearranging seating to minimise sensory overload can make a significant difference for students who are easily overwhelmed by noise or movement. Providing universal sensory tools—such as noise-cancelling headphones, fidget items, or access to quiet areas—ensures that all students have options for self-regulation. These adjustments aren’t just about supporting neurodivergent students; they benefit the entire class by creating a calmer, more accessible learning environment.
Beyond physical changes, BICPs require teachers to engage in ongoing professional growth. Training in recognising neurodivergent communication styles is crucial, as it helps educators see behaviours like stimming or echolalia not as disruptions but as valid forms of expression. Understanding these behaviours shifts the focus from control to connection, fostering relationships built on trust and respect.
For this shift to succeed, teachers must let go of the traditional vision of a classroom centred around their preferences and authority. The need to “fix” children stems from a mindset that prioritises the teacher’s control over the student’s experience. BICPs invite educators to view their role differently—not as rulers of a fixed space, but as facilitators of a dynamic and responsive environment. By choosing to embrace this shift willingly, rather than begrudgingly, teachers can move beyond ego and create classrooms where every student feels they belong. It is not about giving up control but about redefining what it means to lead: with compassion, adaptability, and an unwavering commitment to equity.
The Broader Goal: Systemic Transformation
The current focus of FBAs is on individual students, dissecting their actions to identify the roots of behaviours deemed disruptive. While this may provide a surface-level understanding, it fails to address the systemic factors that often create or exacerbate these behavioural challenges. Schools need to shift their perspective from fixing the individual to improving the overall user experience of the classroom. Much like a customer service philosophy where “the customer is always right,” this approach assumes that if students struggle, the issue lies not in them, but in the design of the system they are navigating.
True systemic transformation requires us to view classrooms as dynamic ecosystems rather than static spaces. Each classroom must adapt to the needs of its students, rather than demanding students conform to rigid norms. This vision for the future begins with elevating neurodivergent voices in policy-making, ensuring those most affected by educational practices have a say in shaping them. It extends to fostering inclusive environments where diverse behaviours and communication styles are not just tolerated but celebrated. Classrooms, after all, are active participants in shaping behaviour, and their design must reflect this responsibility.
To achieve this, schools must invest in the time and resources necessary for teachers to create classroom ecologies tailored to their students. This preparation cannot be left to unpaid hours squeezed into evenings and weekends. Teachers need paid planning time ahead of each school year to thoughtfully design spaces that anticipate and meet the needs of incoming students. As classes change from year to year, so too should the classroom environment, evolving in response to the unique composition of its occupants.
This transformation requires a cultural shift within education. It means recognising that when a student “fails” to thrive, it is not their failure but a signal that the environment has not adapted to meet their needs. By prioritising the user experience of every student, we can move beyond the punitive and prescriptive practices of FBAs to build classrooms rooted in empathy, flexibility, and care. When we stop demanding conformity and start embracing individuality, we not only create better outcomes for neurodivergent students but for all who enter the classroom. It’s time to design with students in mind, because in education, as in any great service, the customer is always right.
A Quick Digression: Alexithymia and Classroom Behaviours
Throughout my years of teacher training, professional development sessions, and countless communications from my employer and trade organisations, one striking omission has stood out: the word “alexithymia.” Not once was it mentioned, even in specialised preparation as a special educator - nor is it found in the FBA guidance document. For a term so deeply relevant to understanding autistic individuals, its absence is telling. It points to a significant gap in how educators, and even those in adjacent fields like applied behaviour analysis, are equipped to support the neurodivergent students they serve.
Alexithymia, broadly defined, refers to difficulties in identifying and articulating one’s emotions. It is not a condition exclusive to autism, but it is a trait that overlaps significantly with the autistic population—myself included. The majority of autistic individuals experience some degree of alexithymia, making it a key factor in understanding behaviours that might otherwise be dismissed or misunderstood. This disparity in training and awareness is one of the many issues that compelled me to write No Place for Autism?. My goal was to provide research and context for this way of being, illuminating the lived experiences of those for whom traditional frameworks, like FBAs, are woefully inadequate.
The consequences of ignoring alexithymia in educational and behavioural contexts are significant. In the BCBA (Board Certified Behaviour Analyst) industry, for instance, there is almost no acknowledgement of alexithymia. This omission is reflected in how certain behaviours are treated. Behaviours that appear to “come out of nowhere” or seem resistant to “extinguishing” often baffle practitioners. But for those of us who are autistic, the answer lies in the interplay between alexithymia and hyper-empathy. We feel deeply but may struggle to trace the origins of those feelings or articulate them in ways that make sense to the frameworks and language of the neuro-majority. This disconnect is not a refusal to comply but a fundamental difference in processing and expression.
By failing to account for alexithymia and autistic hyper-empathy, systems designed to manage behaviour often miss the mark entirely. Educators who lack an understanding of these aspects of the autistic experience are unable to interpret what is unfolding in their classrooms, particularly when one student’s overwhelm cascades into the rest of the group. This phenomenon, where the intense emotions or distress of one autistic student seem to “transfer” to others, can leave teachers feeling as though they’ve suddenly lost control of the room. But this isn’t chaos; it’s the interplay of hyper-empathy and alexithymia at work—qualities that remain invisible to those who don’t understand our neurotype or ways of being.
When teachers don’t grasp the underlying dynamics, they struggle to make sense of what their eyes are seeing. A student’s sudden distress, seemingly unprovoked, might be misinterpreted as deliberate defiance or attention-seeking. However, the transfer of emotional energy between autistic individuals can be incredibly rapid, often amplifying the emotional atmosphere of the classroom. If this distress spreads unchecked, the situation can quickly spiral, underscoring the importance of managing classroom energy with care and intention to maintain a supportive environment for all students. Unable to recognise the role that neurodivergent processing plays in these moments, teachers are left without the language to describe the behaviours accurately. And when the root causes remain obscure, the solutions sought are often inappropriate—tools and interventions aimed at suppressing behaviours rather than understanding and addressing their origins.
This lack of understanding not only pathologises natural neurodivergent responses but also creates a cycle of frustration for both students and educators. Teachers, overwhelmed by the apparent unpredictability of these behaviours, may turn to rigid behavioural management strategies that fail to address the environmental or emotional triggers at play. Meanwhile, autistic students, whose distress is compounded by being misunderstood, are left unsupported, their needs unacknowledged.
Addressing this gap requires more than surface-level awareness. It demands a fundamental shift in how behaviours are interpreted and supported in schools. Recognising alexithymia and hyper-empathy as intrinsic aspects of the autistic experience is not optional—it is essential. Teachers must be equipped to see beyond the behaviours themselves, to understand the emotional and sensory dynamics driving them. Without this understanding, educators are not just missing a piece of the puzzle; they are using the wrong tools to solve it entirely, leaving their classrooms—and their students—at a loss. To truly support autistic students, we must first understand them as they are, not as we expect them to be.
Final thoughts …
Functional Behavioural Assessments may claim to promote inclusion, but their foundation in behaviourism—a framework rooted in control and compliance—undermines this promise. Behaviourism, and by extension FBAs, is a product of its time, emerging from a lineage deeply entangled with eugenics. This is not a system autistic individuals created or endorsed; it is one imposed upon us, often at the expense of our authenticity and well-being. Its deficit-based approach pathologises behaviours instead of seeking to understand and support the individuals exhibiting them. Paired with a lack of transparency about whose voices shaped the current guidance, FBAs perpetuate a system that prioritises conformity over care.
It doesn’t have to be this way. We must move beyond assessing behaviours to auditing environments. Classroom environmental audits offer a proactive, compassionate alternative to FBAs. They shift the focus from “fixing” the student to addressing the systemic and environmental barriers that contribute to distress. These audits must centre collaboration with neurodivergent individuals—those who understand, through lived experience, the impact of poorly designed spaces and systems. Inclusive classrooms cannot exist without the input of those they aim to serve.
The path forward is clear: we must prioritise systemic reforms that elevate neurodivergent voices, foster environments that embrace diversity, and abandon practices that view students as problems to be managed. When a student struggles, their behaviour is not a failure but a message—a sign that something in the system needs to change. As with the canary in the coal mine, the solution is not to fix the bird but to clear the air. If we truly care about inclusion, we must commit to fixing the mine. Only then can our classrooms become places where all students can thrive.