A Resource for Teachers, Clinicians, Parents, and Students by the Brain Injury Association of New York State.


Individuals are described as noncompliant if they fail to or refuse to follow the instructions of an authority figure or conform to rules. These individuals may routinely fail to complete assigned homework, expected household chores, and other expected activities. The individual may be charming, pleasant, and apologetic when the problem is called to his attention. Alternatively, he may be sullen and openly defiant when confronted with his behavior.

It is critical to note the difference between “failure to comply” and “refusal to comply”. Failure to comply has many possible explanations (e.g., the person did not understand the instructions; forgot or did not know the rule; was simply slow to start) and does not imply any specific intention or motivation on the part of the person. In contrast, refusal to comply suggests an oppositional intention on the part of the individual – willful noncompliance – and is normally considered a behavior problem. In cases of extreme willful noncompliance, a diagnosis of oppositional-defiant disorder is often made.

In practice, most people use the term “noncompliance” to mean that the person refuses to follow an instruction or request, or obey a rule. That is, it is assumed that the act of refusal is conscious and willful. Unfortunately, many times staff or family members make the move from DOES not do to WILL not do with inadequate evidence that the person’s act is willful. That is, there is a tendency to interpret failure to comply as willful. The end product is that others then attempt to increase control over the person in order to increase compliance.

Deciding that the individual is behaving in a willfully noncompliant manner assumes that he: (1) is aware that the person issuing the instruction is a proper authority figure, (2) understands the instruction, (3) remembers the instruction, (4) is able to control impulses, (5) has adequate initiation ability, and (6) is not especially slow in formulating responses. Each of these assumptions is associated with brain injury (see below) and should be ruled out before making a judgment that the behavior is willfully noncompliant.

Furthermore, genuine noncompliance (i.e., willfully refusing to follow instructions) may represent a variety of different functions or communication intents for the student. For example, the student may be saying, in effect, “I need some sense of control and this is how I get it.” Or, “I can’t do what you are asking me to do.” Or, “I feel like showing off for my peers.” Or, “I am depressed and can’t do anything today.” Or “I am sick.” And there are other possibilities. Clearly an understanding of the function of the act of noncompliance (i.e., its communication intent) is necessary before intervention decisions can be made. In general, functional analysis of behavior must precede intervention decisions. [See Tutorials on Behavior Management: Prevention Strategies; Behavior Management: Contingency Management.]


Student behaviors that are labeled “noncompliant” are commonly identified as the greatest problem for school staff and a significant problem for families as well. School and classroom management practices (and in many ways home life as well) are built on two assumptions: (1) that students understand the rules and routines of the classroom and home, and are willing and able to follow those rules and routines with minimal intervention and support; and (2) that the students recognize that parents and teachers are authority figures whose instructions and rules are to be followed. Lack of compliance disrupts home and school routines and results in staff and parent discontent.

Deciding that the student with TBI is behaving in a willfully noncompliant manner assumes the following:

  1. The student is aware that others issuing the instruction are proper authority figures. Social cognition and social perception deficits are common after brain injury and may affect this awareness. [See Tutorial on Social Perception.]
  2. The student remembers the instruction or rule at the time he is supposed to comply. Memory problems are common after brain injury. [See Tutorial on Memory.]
  3. The student understands the instruction or rule, and understands that the instruction is to be followed now. Impaired attention, orientation to task, and language processing after brain injury may cause one to question this assumption. [See Tutorials on Attention; Language Comprehension.]
  4. The student is in control of his impulses; the response is not a result of brain-injury related impulsiveness, very common after brain injury. [See Tutorial on Impulsiveness/Disinhibition.]
  5. The student does not have initiation difficulties and can volitionally stop or start the behavior in question. [See Tutorial on Initiation.]
  6. The student’s failure to respond is not a result of brain-injury related delayed responding or generally slowed processing, common after brain injury. [See Tutorial on Slow Information Processing.]

Noncompliance is highlighted as a common problem for students with brain injury in part because of the ease with which a wide variety of the student’s co-existing difficulties are misidentified as willful noncompliance. Impulsiveness, initiation impairment, memory problems, slowed responses, impaired social perception, impaired attention, weak language processing, all common after brain injury, can lead to an incorrect judgment of noncompliant behavior. Noncompliance might also be a symptom of emotional distress or depression. Willful noncompliance may also be associated with brain injury as the student reacts negatively to new rules and restrictions imposed by the injury.

For these reasons, what may appear to be willful noncompliance may not in fact be willful. Careful assessment is mandatory.

Whether the adult judgment of willful noncompliance is accurate or inaccurate, it often results in staff and parents imposing greater and more obvious controls over the student’s behavior. This often leads to a negative student reaction, which in turn results in greater parent or staff control. This is the classic control battle that may lead to severe problematic behavior from the student (e.g., aggression, elopement, verbal disruption).

In schools and at home, the common response to willful noncompliance is punishment. In schools, punishments may range from losing recess, or other enjoyable activities, to suspension. At home, punishment may include losing privileges, losing time spent in enjoyable activities, or “grounding”. The assumption is that the student will recognize the connection between his behavior and the punitive consequences, and therefore modify his behavior in response. However, many students with brain injury (especially frontal lobe injury) fail to make the connection between their behavior and its consequence. Or if they make the connection intellectually, it does not result in improved behavior. Therefore, behavior management systems that rely on punishments are rarely successful and most often make the problem worse. [See Tutorials on Behavior Management: Contingency Management; Behavior Management: Prevention Strategies; Positive Behavior Supports]


Careful Analysis of the Behavior: Step 1 in all management plans is to ensure accurate understanding of the behavior. In the case of apparently willful noncompliance, staff (or family) must first rule out the possibility that the apparently willful act of noncompliance is in fact the result of the student’s co-existing problems with impulsiveness, memory or attention problems, initiation impairment, lack of understanding, slowed responding, or depression. If it is discovered that one of more of these problems is primary, then intervention and support plans should be directed at those identified problems. [See Tutorials on Impulsiveness, Memory, Attention, Initiation, Language Comprehension, Slow Information Processing, Depression.]

Assuming that the student’s behavior is truly willful noncompliance, family and staff must then attempt to understand the function of the behavior. For example, if the student is saying, in effect, “I need some sense of control and this is how I get it,” family and staff should offer legitimate opportunities for student choice and control at times when this is appropriate. Or if the student is saying, in effect,“I can’t do what you are asking me to do,” family and staff must make supports available so that the student can have confidence that the task is do-able. Or if the student is saying, in effect, “I feel like showing off for my peers,” family and staff might either create greater isolation during intense work times or offer other legitimate opportunities for the student to be a “big shot” in the eyes of peers.

The point is that intervention should be designed to prevent the willful noncompliant behavior [See Tutorials on Behavior Management: Prevention Strategies; Positive Behavior Supports] and must be adjusted to the function of the behavior. To the extent that the student is truly oppositional, threats, punishment, power struggles, coaxing, nagging, and the like generally make the problem worse.

General Management Strategies for Noncompliant Behavior

1. Collaborative negotiation of task expectations: Staff and family members should take time to negotiate with the student reasonable expectations for work completion and supports to ensure that the work is do-able and that the student perceives it as do-able. Furthermore, within work routines there should be reasonable opportunities for student choice. Oppositional students are often looking for a sense of control in their lives; planned choices and control over work tasks may be essential for these students.

Advantages: Negotiation creates relationships that are collaborative and positive, reducing the likelihood that instructions from authority figures are interpreted as a challenge – threatening the downward spiral of control battles. Furthermore, there is no real need for refusal if the plan for activities is made by the individual – she is following her plan not simply complying with the demands of others.

Disadvantages: Negotiation can be time consuming and difficult to implement in the family setting or in a larger classroom setting. Many adults teachers are concerned that this kind of negotiation gives too much “power” to the student (although it is really the adult exercising intelligent power) and that siblings’ or other students’ behaviors may worsen when they see that the adult “is not in control”.

2. Concrete Daily Goal-Obstacle-Plan-Do-Review Routines: [See Tutorial on Self-Regulation/Executive Function Routines.] In working with students with brain injury and others, it is wise to engage the student in routine planning sessions that are organized around the Goal (What are you trying to accomplish?), Obstacle (Why might this be hard?) Plan (How can you get this done?), Do, and Review (How’d you do? What worked for you? What didn’t work for you?). These planning sessions, which can be very short, ensure that the student is completely clear about expectations and the means to achieve them. These sessions also create a collaborative relationship that reduces the need for defiant noncompliance. In the classroom or family setting, these routines can be whole-class or family routines, not necessarily individualized to the noncompliant student.

Advantages: Respectful engagement in planning is often helpful in working with noncompliant students. Furthermore, written or picture routines (plans) provide clarity of expectations for the student. This is especially helpful for students with memory and organizational difficulties. Increased predictability of expectations increases the likelihood that a student will comply with those expectations – in general, the ability to predict the course of one’s day decreases the probability of behavior problems. This kind of support keeps the accountability and responsibility for behavior clearly in the hands of the student, reducing the need for defiance in response to external authority.

Disadvantages: This routine can be difficult to implement at first. However, once it becomes part of the daily routine, it is as easy as any other teacher or parent routine.

3. Errorless Teaching/Learning Strategies: In many cases, student noncompliance is a result of the student lacking confidence that she can accomplish the task. In such cases, staff should attempt as much as possible to use errorless teaching/learning procedures. Furthermore, there are many additional reasons to use these procedures for students with brain injury. [See Tutorial on Errorless Learning]

Video Illustration of Errorless Learning.
Click HERE.

Advantages: Errorless teaching/learning procedures reduce noncompliance based on fear of failure and also reduce the need for negative corrective feedback, thereby reducing the student’s refusal opportunities. Errorless teaching/learning procedures also increase the opportunities for positive feedback, so there is an increase in positive behavioral momentum to help overcome difficult behaviors. [See Tutorial on Positive Behavioral Supports]

Disadvantages: Errorless teaching/learning procedures can be impractical in younger children or in a grade level classroom setting, although some classroom curricula (e.g., Direct Instruction programs) are based on a philosophy of errorless learning. Some adults complain that these procedures “coddle” students who need to learn that they must comply with the instructions of authority figures even if they don’t want to. This concern is legitimate. However, the question is how to get students to that point if they are currently succeeding with their oppositional noncompliance. The procedures outlined in this section can be thought of as an initial stage in a process that will ultimately result in a more compliant student.

4. Quiet, Confident Authority: In interacting with noncompliant students, whether willful or not, parents and teachers should exercise their authority in a quiet and confident manner. They should make reasonable expectations clear, offer needed support, remain consistent in their discipline practices, and remain calm. When parents or teachers appear agitated, anxious, or lacking in confidence, the silent communication to the noncompliant student may be that he controls the adult’s behavior and emotional states with his behavior. He is in charge – and he may like that!

5. Assertiveness Training: In some cases, the student’s noncompliance is her indirect (i.e., passive) way of saying, “I can’t do this; it’s too hard.” In this case, staff and parents should help the student to explicitly identify the difficulty level of the task and ask for help. [See Self-Regulation/Executive Function Routines.]

Advantages: If the student is offered a positive communication alternative to the negative noncompliant behavior, there may no longer be a need for noncompliance; it may disappear.

Disadvantages: The student may become overly assertive or demanding. In this case, the negotiation outlined in #1 above is relevant.

6. Reactive Strategies: Redirection and Disengagement: On those occasions when noncompliance has not been effectively prevented, family and staff need to react in a way that does not exacerbate the problem behavior. The first reactive strategy is redirection. If the student’s attention can be drawn away from the negative interaction, it may be possible to then return to the task at hand without resistance. In the face of genuine resistance that cannot be overcome with redirection, staff should temporarily disengage, possibly leaving the student (e.g., “I see you’re not ready; let me know when you are ready”), and then return when the student appears more ready. The rationale for disengagement is that power battles intensify when both parties are actively asserting their power.

Advantages: These reactive strategies reduce confrontation between the student and the authority figure, thereby reducing escalation of non-compliance into other more problematic behavior.

Disadvantages: It is possible that these strategies may result in initial increases in problem behaviors causing greater difficulty for the classroom (and at home) over the short run.

7. Reactive Strategies: Rewards: Social and other natural rewards for compliance should be a salient component of home and school cultures. At school, praise should be used liberally (e.g., “That’s terrific; you’re doing exactly what I asked and you’re doing a great job!”). At home, parents can routinely reward completed homework with natural comments such as, “Great job; because you’re done with your homework, there’s plenty of time for video games!”

See Tutorials on Behavior Management: Prevention Strategies; Behavior Management: Contingency Management; Discipline; Positive Behavior Supports; Motivation.

Written by Mark Ylvisaker, Ph.D. with the assistance of Mary Hibbard, Ph.D. and Timothy Feeney, Ph.D.

A program of the Brain Injury Association of New York State, and funded by the Developmental Disabilities Planning Council.

Copyright 2006, by
The Brain Injury Association of New York State
10 Colvin Avenue, Albany, NY 12206 - Phone: (518) 459-7911 - Fax: (518) 482-5285

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