Response to Intervention (RTI) has far reaching implications for children with Specific Learning Disabilities (SLD); therefore, it is imperative that LDA responds to this initiative by supporting those components of RTI that can benefit individuals with SLD and identifying other components that are not in their best interest.

LDA welcomes ideas, research, and research-based practices for improving instruction and services for individuals with SLD. As new initiatives are introduced, LDA must be vigilant to ensure that they are of benefit to children and youth with SLD. It is in this spirit that this position statement is written.

The 2004 amendments to the Individuals with Disabilities Education Act (IDEA), [Sec.300.8(c)(10)] defines Specific Learning Disabilities as:

(A); ”GENERAL – Specific learning disability means a disorder in one or more of the basic psychological processes involved in understanding or in using language, spoken or written, that may manifest itself in the imperfect ability to listen, think, speak, read, write, spell, or do mathematical calculations…”

These amendments also added procedures for identifying children with SLD and stipulated that states must adopt criteria for determining whether a child has a Specific Learning Disability as described above. It was further stipulated that states:

  • Must not require the use of a severe discrepancy between intellectual ability and achievement for determining whether a child has a Specific Learning Disability, as defined in 34 CFR 300.8(c)(10)
  • Must permit the use of a process based on the child’s response to scientific, research- based intervention; and
  • May permit the use of other alternative research-based procedures for determining whether a child has a Specific Learning Disability, as defined in 34 CFR 300.8(c)(10).

The Response to Intervention Process

Prior to IDEA 2004’s recognition of “a process based on the child’s response to scientific, research-based intervention” as an SLD identification process, RTI had been regarded as a prevention model to limit or prevent academic failure for students who are having difficulty learning. Although there is no single RTI model, the many variations that have emerged since 2004 use a two-to-five tiered model. The term MTSS (Multi Tier System of Support) is sometimes used interchangeably with RTI. Each RTI or MTSS tier provides increasingly individualized instruction, continuous monitoring of progress to calculate gains, and criteria for changing interventions and/or tiers through a team decision-making process. In general, the tiers would include:

Tier I: high quality instruction and behavioral supports provided in general education classrooms.

Tier II: small group instruction – intensive specialized interventions provided with consistency by highly trained teachers.

Tier III:  more individualized intervention and/or referral for special education.

Another purpose of RTI is to serve as part of a comprehensive evaluation for SLD. Local Education Agencies must use the eligibility criteria developed by their state. States must permit, and may require, using RTI as a part of eligibility criteria.

LDA supports the promise of RTI as an early intervention process initiated by general education to ensure that, at the first sign of school problems, students will receive academic supports including:

  • Early, high-quality, scientific research-based interventions
  • Continuous monitoring of student performance and progress during interventions
  • Use of response data to change the intensity or type of subsequent interventions
  • Parents and families informed and involved in team decision making throughout the intervention process

LDA recognizes the difficulties in the effective implementation of RTI as a system-wide initiative and has concerns about the following:

  • The lack of availability of “scientific, research-based interventions” for all ages and all academic domains. While there is much scientific evidence to help educators teach early reading skills (e.g., phonological awareness and beginning decoding skills), there is less research-based knowledge about how to teach reading comprehension, math, spelling, writing, or content areas of science and social studies.
  • The need for ongoing professional development for general education personnel who will be implementing RTI. 
  • The inconsistent implementation of researched-based interventions with fidelity is a continuing, pressing concern.
  • The need for more research regarding implementation of RTI in middle and high school students.
  • The need for school districts to develop consistency in the design of RTI models across local school agencies.
  • The lack of controlled studies regarding the use of RTI in SLD determination. 

LDA supports RTI as one component of a comprehensive determination of eligibility, specifically:

  • LDA supports the appropriate implementation of the first two tiers of RTI to ensure that the children who are eventually identified as having SLD participated in programs providing effective instruction and, when appropriate, intervention. Such practices should help reduce so-called false positives (identification of children who fail to achieve academic goals because, in fact, they have not received appropriate instruction).

It is essential that parents be aware of their right to send a written request to the school system that their child receive a comprehensive evaluation for identification/eligibility for special education services at any time during the RTI process.

LDA does not support the use of an RTI process as the sole evaluative process for the identification of SLD for these reasons:

  • The use of a RTI instructional/intervention framework should not be construed as the only, or as the most important process for SLD identification. Practitioners in some states already use RTI in this manner, resulting in low-achievement as a definition of SLD and labeling of students with SLD as having a “non-categorical” disability. This discourages the use of multi-disciplinary evaluation teams and the use of cognitive, language, and perceptual tests. In effect, this subverts many years of clinical practice and empirical research on learning disabilities.
  • Learning disabilities must not be equated with low achievement alone. The RTI low achievement criterion may exclude some high-ability students with SLD from special education despite the fact that IDEA regulations (Sec 300.301) state: “FAPE (free appropriate public education) is available to any individual child with a disability who needs special education and related services even though the child has not failed or been retained in a course or grade and is advancing from grade to grade.”
  • Research studies indicate that lack of fidelity of RTI implementation ( Fuchs, D., Fuchs, L., 2017), as well as the use of different methods and measures for determining progress and growth make RTI an arbitrary method for determining SLD. (Fuchs, Doug, February 19,  2021, [LDA Conference Presentation]; Richards -Tutor, C., Solari, E. et. al. 2012).

Data documenting the child’s response or failure to respond to intervention is critically important in a comprehensive evaluation process. Additionally, IDEA regulations specify that a comprehensive evaluation must use a variety of assessment tools, must assess all areas of suspected disability (IDEA), [Sec.300.304(c)(4)] and must use technical sound instruments to assess the relative contribution of cognitive and behavioral factors. (IDEA), [Sec.300.304(b)(3)]. 

It is the position of LDA that all evaluations for Specific Learning Disabilities must include assessment of cognitive processes.


Fuchs, Doug, February 19,  2021 , A three minute argument against using RTI  to    identify children and youth with LD. [Conference Presentation] Feb. 18-21, 2021 LDA  58th Annual International Conference ,  Dallas, Tx. USA, Virtual 

Fuchs, D., Fuchs, L., (2017 ) Critique of the national evaluation of response to intervention: a case for simpler frameworks. Exceptional Children Vol 83 (3) 255-268.Richards-Tutor, C., Solari, E. (2012), Response to intervention for English    learners: examining models for determining response and non response. Assessment for Effective Intervention. XX(X)1-13.)