What counts as functional performance?

It can include communication, social participation, self-regulation, behavior, organization, mobility, adaptive routines, independence, and other nonacademic skills that affect participation in school.

Can teacher observations be data?

Yes when they are recorded with enough definition to be interpretable: setting, opportunity, behavior, prompt level, frequency, duration, or another observable dimension.

Should staff support be included in the baseline?

Yes. Distinguish independent performance from performance with visual, verbal, physical, technological, or other support so the team can see the student's actual level of independence.

Do all functional needs require their own annual goal?

Not necessarily. The IEP must address identified needs appropriately, which may occur through goals, services, accommodations, supports, behavior planning, or other components depending on the individual student.

Functional Present Levels in an IEP: Write Independence, Communication, Behavior, and Access With Data

Write functional present levels with observable baselines for routines, communication, self-regulation, behavior, organization, mobility, and independence.

Functional present levels describe how a student participates in school beyond academic test scores. They can cover communication, self-regulation, behavior, social participation, organization, mobility, adaptive routines, use of assistive technology, and other skills that affect access. The same quality rule applies as in academics: replace impressions with observable performance and explain the educational impact.

Describe the routine where the skill matters

“Needs help with independence” is not a baseline. “During arrival, Tessa independently hangs her backpack and checks in but requires two to four adult verbal reminders to unpack materials and begin the posted warm-up on four of five observed mornings” gives the team a routine, behaviors, prompt level, and frequency.

Record prompts because adult support can hide the baseline

A student may appear successful only because staff anticipate every need. Observe what happens after the ordinary environmental cue before adding assistance. Code whether the student responds independently, to a visual cue, to an indirect verbal cue, to a direct verbal direction, or to more intensive support. This prevents “completes routine” from disguising full adult dependence.

Communication data should show function and mode

Instead of “limited communication,” write what the student communicates and how: “Using her speech-generating device, Ana independently requests preferred items in 8 of 10 observed opportunities but requests help in 1 of 8 difficult-task opportunities; in the remaining seven she pushes materials away or waits for adult assistance.” That pattern can lead to a functional communication goal.

Behavior descriptions should avoid moral labels

Replace “defiant,” “lazy,” or “attention seeking” with the behavior and context. “When independent writing is assigned for more than ten minutes, Marcus leaves his seat and moves more than six feet from the work area in 5 of 8 observed sessions; episodes last 2–12 minutes.” If the team has functional assessment information, summarize the relevant function hypothesis separately rather than presenting it as a fact without data.

Independence can be measured as latency or completion

For organization and initiation, time may be the clearest dimension. “After the visual schedule changes to math, Ji begins the first listed task within two minutes on 3 of 10 days without an adult cue; with one verbal reminder, he begins on an additional 5 days.” That baseline can support a goal targeting initiation and prompt fading.

Include environmental conditions that change access

Functional performance is often context-sensitive. A student may navigate hallways independently during regular passing periods but need adult support during assemblies, crowded dismissal, or unfamiliar routes. A student may use coping strategies in a quiet resource room but not in a noisy cafeteria. Naming the setting keeps the team from overgeneralizing one successful observation.

Link the functional need to school participation

Explain why the baseline matters educationally: repeated adult prompting delays entry into instruction; inability to request help leads to abandoned work; difficulty navigating transitions causes missed class time; a communication barrier limits participation in group problem solving. This connection turns a behavior count into an IEP-relevant need.

Show what already works

Functional present levels should include supports and strengths. If a picture schedule cuts transition time from seven minutes to two, say so. If the student independently checks a digital calendar but does not yet transfer assignments into it, that skill is a foundation for instruction. Effective supports belong in the current-performance picture because the IEP Team must decide what to continue.

A functional present-level example

During the final ten minutes of the school day, Eli independently checks the posted packing list and places his device in his backpack on 5 of 5 days. He packs the required homework folder and subject materials without an adult verbal reminder on 1 of 5 days; on the other four days he requires two to three reminders and has arrived home without an assigned item twice in the last three weeks. When the checklist is reviewed one-to-one before dismissal, he packs all listed items. Difficulty independently completing the multi-step dismissal routine affects assignment completion and requires ongoing adult support. Eli needs instruction in using the checklist to self-monitor the entire routine.

Make the next IEP component traceable

After writing the paragraph, ask what the IEP does about the need. Does it lead to a measurable annual goal, a supplementary aid, staff support, related service, behavior support, or another documented response? Functional present levels should not become a catalog of difficulties that never appears again in the program.

Describe independence in terms of support intensity

Functional performance often changes because the amount of adult help changes, even when the final task looks the same. Record whether the student completes the routine independently, with a visual cue, after one verbal prompt, with repeated prompting, or with physical assistance where appropriate. This creates a baseline that can show meaningful growth toward independence without pretending the only outcome is “can/cannot do.”