Almost all problem behavior interferes with learning to some extent. The intention behind IDEA's requirement to consider positive behavioral interventions and supports is for it to apply to behavior that is reoccurring or is likely to recur. In other words, if the behavior warrents special action to address it, and it impedes learning, the IEP team has to consider using PBIS. Since this is a one-time incident that is not likely to recur, PBIS does not have to be considered (although it still can be).
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