Re:   8 VAC 20-81-10, pp 27,28:  I OPPOSE CHANGES IN HOW FBAs SHOULD BE DEVELOPED – FBAs should NOT be merely a review of “existing” data, and which doesn’t require the input of a parent.  FBAs are an all-important and UNDER-utilized tool and not really understood by most school personnel.  What VDOE should do is make mandatory the training of all school personnel re: FBAs, and utilizing the current language – and then followup, monitor  and enforce the requirement for training.   Functional Behavior Assessments (FBAs)  [8 VAC 20-81-10, pg. 27-28].  Again, Parental Input is KEY and important in order to help interpret and determine ANTECEDENTS to behaviors and situations where behaviors occur.   The expertise of the child’s parent(s) is vital to FBAs being given and used fairly, accurately, and appropriately.

** Please note: I agree with and endorse the comments made by the Virginia Office for Protection and Advocacy, The Virginia Coalition for Students with Disabilities, and The Arc of Virginia **