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A Parent's Guide to Response to Intervention (RTI)
by Susan Bruce

an active classroomWhen IDEA was reauthorized in 2004 some new buzz words emerged. One term is Response to Intervention (RTI).  Although response to intervention is not actually new, it is very new to IDEA, parents, and to many school districts.

RTI in IDEA and “scientifically research based instruction” in IDEA and NCLB emphasize the quality of instruction ALL children receive. NCLB and IDEA raise the bar in education by attempting to ensure that ALL children receive high quality instruction. The purpose of RTI is to catch struggling children early, provide appropriate instruction, and prevent the need to refer the child for special education. This concept offers hope and fear in advocates and parents.

In an attempt by the US Department of Education to eliminate the wall that separates regular and special education, school districts may use 15% of IDEA funding for early intervention services in regular education - RTI.

RTI and Hope for Better Instruction

RTI offers hope that all children will receive better and more adequate instruction in math and reading. RTI provides a new and different way to identify students with specific learning disabilities. 

But, there are important issues that parents need to be aware of. If we, as parents, are not educated on the RTI process and what IDEA requires, our schools may fail to identify some children who do have specific learning disabilities.

I concur with the experts who say that many children have not received the type of instruction they need to be successful. The regular education core curriculum often leaves out one or more of the five essential components required for effective reading instruction by the National Reading Panel. When used as intended, RTI should eliminate this problem.

What is RTI?

RTI is a tiered process of instruction that allows schools to identify struggling students early and provide appropriate instructional interventions. Early intervention means more chances for success and less need for special education services.  RTI would also address the needs of children who previously did not qualify for special education.

RTI Should be a School Wide Model

Although, a schools model may look different, there are several essential and necessary components that parents need be aware of:

  • Scientifically Research Based Instruction - All children should receive research based reading instruction in the general education classroom.
  • School Wide Screening - Schools should screen all children early to determine if they are “at risk.”
  • Continuous Progress Monitoring - Schools should monitor the progress of all “at risk” children to determine if they are benefiting from instruction.
  • Fidelity - Schools must use any program or curriculum correctly and as intended.
  • Procedural Safeguards - Schools must ensure parents are aware of their rights.


Tiers in RTI

RTI is a delivered to students in tiers or levels.  There is much discussion about how many tiers should be in RTI models. The three-tiered model is the most common. This means there are different levels of intervention, based on the needs of the student. The level of intervention increases in intensity if a child does not respond to instruction.

IDEA does not specify how many tiers an RTI model must contain. IDEA does not specify how long a child must remain in one tier before moving to the next level. The US Department of Education left this to the states to determine.

What RTI is NOT

  • Special seating in classroom
  • Shortened assignments
  • Parent-teacher conferences
  • Suspension
  • Retention
  • “More of the same” general classroom instruction

What IDEA Says about RTI and SLD

Section 300.307 of the federal Special Education Regulations says that states must adopt criteria for determining whether a child has a specific learning disability.  States must not require the use of a severe discrepancy between intellectual ability and achievement model. States must permit the use of a process based on the child's response to scientific, research-based intervention.

When IDEA was reauthorized in 2004, RTI was added in an attempt to bring IDEA in line with NCLB and Reading First. In the Commentary to the Regulations, US DOE acknowledged that identification “models that incorporate RTI represent a shift in special education toward goals of better achievement and improved behavioral outcomes for children with specific learning disability (SLD).”

Concerns about the RTI Process

I agree with the experts who say that many children are identified with specific learning disabilities because they do not receive adequate instruction in reading and math. In other words, these children are not making sufficient progress because they receive poor instruction, not because they have a learning disability.

I also believe some children have specific learning disabilities.

My fear is that school districts may use RTI to delay, or worse, to not evaluate children who are suspected of having specific learning disabilities.

OSEP Memorandum - RTI process cannot be used to delay-deny an evaluation for eligibility under IDEA. Office of Special Education Programs to State Directors of Special Education, 01/21/11.

In the Commentary to the federal special education regulations, many people expressed these same concerns. Because of these comments, and to ensure that parents are notified of their right to request an evaluation at any time, the US Department of Education added the following to the federal regulation Section 300.311 (Commentary in the Federal Register at p. 46658):

(a) For a child suspected of having a specific learning disability, the documentation of the determination of eligibility, as required in 300.306(a)(2), must contain a statement of--

...

      (7) If the child has participated in a process that assesses the child’s response to scientific, research-based    intervention

(i) The instructional strategies used and the student-centered data collected; and
(ii) The documentation that the child’s parents were notified about—

(A) The State’s policies regarding the amount and nature of student performance data that would be collected and the general education services that would be provided;
(B) Strategies for increasing the child’s rate of learning; and
(C) The parents’ right to request an evaluation.

(b) Each group member must certify in writing whether the report reflects the member’s conclusion. If it does not reflect the member’s conclusion, the group member must submit a separate statement presenting the member’s conclusions.

What Does RTI Mean for our Kids?

  • States must put into place criteria for determining whether or not a child has a Specific Learning Disability (SLD). 
  • All children should receive appropriate and adequate instruction in the regular education classroom before being referred to special education.
  • The RTI process does not replace the need for a comprehensive evaluation.
  • When a child is participating in an RTI model, parents must be notified of the instructional strategies used, performance data collected, and the general education services that will be provided.
  • Parent’s have the right to request a comprehensive evaluation at any time during the RTI process.
  • Schools must promptly request parental consent to evaluate when a child suspected of having an SLD has not made progress when provided with appropriate instruction.

Questions for Parents and Educators

The federal regulations specify that “States must permit the use of a process based on the child's response to scientific, research-based intervention.” This is not a question of “if” a school district will be required to use RTI, but when. The Commentary to the federal regulations (p.46646-46647) describes the Essential Components of Reading Instruction and references what the ESEA (NCLB) says about appropriate reading instruction including: Phonemic Awareness, Phonics, Vocabulary Development, Reading Fluency, Reading Comprehension Skills.

When should a parent be notified of their right to request an evaluation?

In general, when the child moves from a tier 1 general education (class wide intervention) to a tier 2 (more targeted small group interventions), parents should be informed about what is happening and their rights.

Parents should be advised that their child is not making expected academic progress, the services that will be provided and strategies used to increase their child's progress, and other options that are available to them i.e., the right to request an evaluation under IDEA at any time. (NICHCY's "Building the Legacy Training Curriculum on the IDEA 2004", Module 6 - Early Intervening Services and Response to Intervention.)

Questions Parents Should Ask about RTI

There are specific questions parents should ask to ensure that their child will be accurately identified, and is receiving appropriate instruction to begin with.

  • How many tiers are included the RTI model?
  • How long will my child remain in a tier before moving to the next tier?
  • What scientifically research based form of instruction will the teacher use?
  • What documentation demonstrates the effectiveness of the program?
  • What education journal documents this form of instruction as “peer reviewed”?
  • Does the reading program include the elements defined as "essential components of an effective reading program" set forth by the National Reading Panel?
  • How often will the school monitor my child's progress?
  • What type of progress monitoring will the school use?
  • When will the school report the progress monitoring results to us, the parents, and how often?
  • Will the type of progress monitoring used show how the child is progressing when compared to his peers?
  • What rate of progress should we parents expect?
  • At what point will the school refer our child for an evaluation due to lack of response to instruction?
  • What do your state regulations say about the RTI process?

The Bottom Line

RTI, if used as intended, will be a significant advance in special education. If used incorrectly, RTI will prevent students who have true learning disabilities from receiving the specialized instruction they need.

As with any special educational issue that affects our children, we parents must become experts on RTI. We must educate ourselves, ask questions, and document what we are told.


Meet Susan Bruce

Susan BruceSusan’s most relevant experience is as the mother of four, three of which are students with disabilities. Susan’s next most relevant experience is as a ten year parent advocate and trainer with South Carolina’s former Parent Training and Information Center, PRO*Parents of SC. Susan has trained over 5000 parents, attorneys and advocates during her tenure with PRO*Parents on virtually any topic that has to do with special education and civil rights law.

Susan’s passion for assisting parents and extensive knowledge of the practical application of the Individuals with Disabilities Education Act along with other laws applying to children makes her a fierce advocate for students. The training she has received over the last ten years is second to none. Susan has trained under some the nation’s leading advocates and attorneys, such as Chris Ziegler Dendy, Rick Lavoie, Matt Cohen and Pete Wright of www.wrightslaw.com.

A Board Member of COPAA (Council of Parent Attorneys and Advocates) for 4 years and a member for 7 years, she serves as the board secretary as well as serving on COPAA's executive committee. She also sits on the media relations, advocate and conference committees. Susan has honed her skills by attending COPAA’s National Conference for the last 7 years, presenting sessions at the last 6 and was asked by COPAA to provide the two day advocate training at their preconference for the last 3 years. She has a certificate from the William and Mary School of Law Institute of Special Education Advocacy and holds certificates in non-profit management from Duke and Winthrop University. However, Susan believes that her expertise actually lies in a specialized field that in all actuality can only be obtained by hands on experience and is not taught in any university setting.

Susan continues to hone her skills by continually training, she believes that a vital part of advocacy lies in staying abreast of ever changing case law, scientific research and guidance from the US Department of Education and the Office of Civil Rights.
Susan is a published author, her articles on special education and Section 504 have been published by advocacy organizations all over the country.

Susan Bruce and Mary Eaddy receive ISEA CertificatesJuly 2012 - William and Mary Law School Institute of Special Education Advocacy

Susan Bruce received her certificate from ISEA 2012 at the W&M Law School Institute of Special Education Advocacy for advanced advocates.

Contact information

864-305-9969
susan@spedad.com or susan.spedad@gmail.com

Created 02/27/09
Revised 08/20/15

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