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    Responsiveness to Intervention

    Responsiveness to Intervention:1997 to 2007Renee Bradley

    Louis DanielsonJennifer Doolittle

    The OSEP Uaming DisabilitiesinitiativeIn 1997, during theprocess of reautho-rizing the Individuals with DisabilitiesEducation Act [IDEA), the NationalJoint Committee on Learnitig Dis-abilities [NJCLD) wrote a tetter to theU.S. Office of Special Education Pro-grams [OSEP) expressing concern thatneither early nor accurate identificationof specific learning disabilities [SLD)was occurring [NJCLD, 1997). Theactivities that followed the responsefrom OSEP to the NJCLD letter havebecotne known as the Learning Dis-abilities, or LD, Initiative [Bradley &Danielson, 2004). The LD Initiativebegan as a comprehensive attempt tobring researchers, professional organi-zations, advocacy groups, educators,and other stakeholders to a consensusregarding the identification and imple-mentation of improved procedures forSLD identification. The goal of the LDInitiative was to improve the processand ensure accurate and efficient identi-fication of students with SLD. Relianceon the use of the discrepancy approachto determine eligibility for special edu-cation services had resulted in studentswith SLD not being identified until theyhad experienced multiple years of fail-ure. Additionally, this approach provid-

    ed teachers little information on whichthey could base instructional decisions.The purpose of this article is to pro-vide: [a) a brief description of tbe con-clusions of the LD Initiative and theimpact these conclusions have had, [b)an overview of the new regulationsregarding response to intervention [RTI)

    and the identification of children withSLD, and (c) information about currenttechnical-assistance activities.Early in the work of the LD Initiative,RTi emerged as a concept worthy ofinvestigation. One of the original con-sensus statements from the collabora-tive work on the LD Initiative stated:There should bealternate ways toidentify individuals with SLD inaddition to achievement testing,history, and observations of thechild. Response to quality inter-

    vention is the most promisingmethod of alternate identificationand can both promote effectivepractices in schools and help toclose the gap between identifica-tion and treatment [Bradley,Danielson. & Hailahan, 2002).One reason that RTI was a welcom

    alternative to the traditional discrepancapproach is that teachers no longwould have to wait for students to fabefore the s tudents could receive servies . RTI begins with the implementatioof scientifically based, schoolwidinstructional interventions and promotes intervention at the first indicatioof nonresponse to traditional classroominstruction. In addition, RTI is consitent with a shift of emphasis fromprocess to outcomes for students witdisabilities. This shift is viewed a

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    important both practically and theoreti-cally for the field of SLDwhich histor-ically has concentra ted more on thesearch for the specific condition of SLDand itscause than on intervention effec-tiveness (Bradley, Danielson, & Doo-little, 2005; Ysseldyke, 2002).

    The early collaborative work associ-ated with the OSEP LD Initiative made itpossible for all stakeholdersincludingparents, researchers, and other profes-sionalsto move forward and focus onoperalionalizing the implementat ion ofRTI. In 2001, recognizing the increasingneed for RTl-related research, informa-tion, and technical assistance, OSEPfunded the National Research Center onLearning Disabilities (NRCLD). NRCLDwas given the chal lenging tasks ofinvestigating the effects and impact of avariety of proposed SLD identificationmethods, identifying potential modelsof RTI, and developing technical assis-t ance document s to assist states andlocal entit ies with the ant ic ipatedchange in SLD identification proce-dures. The work of NRCLD was takenInto consideration in the process of cre-a t ing the a m e n d m e n t s lo the Indi-viduals With Disabilities Education Act(IDEA) in 2004.

    One reason that RTI was awelcome alternative to the

    traditional discrepancyapproach is that teacherswould no longer have towait for students to fail

    before the students couldreceive services.

    The 2004 reauthorization of IDEAeffectively removed the longstandingfederal requirement to use the apti-tude/achievemenl discrepancy for iden-tification of SLD, and it now permits RTIto be used as an approach for identifi-cat ion. The amendments to IDEA specif-ically state that "a local educationalagency (LEA) may use a process thatdetermines if the child responds to sci-

    entific, research-based intervention as apart of the eva lua t ion p rocedures . "l 614(b)(6)(A-B, IDEA 2004)]. This lan-guage, combined with other work of th eOSEP LD Initiative, led many sta tes toinvestigate RTI as an approach for SLDidentification.A Fmmeworic forRTIThere are many RTI mode l s be ingimplemented in schools and districtsacross the country. No one model hasemerged as the model of choice, and theU.S. Depar tment of Educat ion (theDepartment) does not recommend orendorse any one specific mode!. In theanalysis of comment s lor the IDEA reg-ulat ions, the Department reinforced theflexibility provided in the regulationsregarding RTI stating:

    New 3OO.3O7(a)(3) Kproposed300.307(a)(4)] recognizes thatthere are alternative models toidentify children with SLD thatare based on sound scientificresearch andgives States flexibili-ty to use these models. For exam-ple, a State could choose to iden-tify children based on absolutelow achievement and considera-tion of exclusionary factors as onecri ter ion for eligibili ty. Otheralternatives might combine fea-tures of different models for iden-tification. We believe the evalua-t ion procedures in sect ion614(b)(2) and (b)(3) of the Actgive the Department the flexibili-ty to allow States to use alterna-t ive , research-based proceduresfor determining whether a childhas an SLD and is eligible for spe-cial education and related servic-es . (USED 2 006, 46648)Although the Department has notendorsed a single model, there is a basic

    framework of RTI em erging in researchand practice that is common to the mostprevalent models. RTI has been concep-tualized as a multi-t iered preventionmodel that has at least three tiers. Thefirst tier, referred to as primary interven-tion, consists of high-quality, research-based instruction in the general educa-tion setting, universal screening to iden-tify at-risk students, and progress moni-toring to detect those students whomight not be responding to this primary

    intervention as expected. Within thismul t i - t iered framework, decisionsregarding movement from one level tothe next are based on the quality of stu-dent responses to research-based inter-ventions. Subsequent levels differ inintensity (i .e., duration, frequency, andt ime) of the research-based interven-tions being delivered, the size of the stu-dent groupings, and the skill level of theservice provider. These secondary inter-ventions typically are 8 to 12 weeks induration. Findings from NRCLD indicatethat the length of t ime needed for thesecond tier can vary, but generally itshould not exceed 8 weeks. Eight weeksis an adequa te amount of t ime to realizethe response or lack of re sponse of astudent to a well -matched evidence-based intervention (Cortiella, 2006).

    [T]here is a basicframework of RTI emerging

    in research and practicethat is common to the most

    prevalent models.

    The finalor tertiarylevel consistsof individualized and intensive inter-vent ions and services, which might ormight not be similar to traditional spe-cial education services. In most models,the lack of appropria te response to themore intensive and more individualizedresearch-based instruction at this terti-ary tier results in referral for a full andindividual evaluation under IDEA. Thequality and amount of information col-lected through progress monitoring of as tuden t ' s r e sponse to i n t e rven t ionsthrough the previous tiers can provideextremely useful data for the teamcharged with determining eligibili ty of astudent for special education services.

    In 2002, NRCLD initiated a process toidentify and record the work and out-comes of a group of potential model RTIsi tes around the country. Although noone site emerged as a comple t e "mode l "that addressed all critical elements iden-tified by NRCLD, there were a group ofsites that distinguished themselves by

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    exhibiting many of the critical elements,such as: (a) implementation of aresearch-based core reading program,(b) universal screening for at-risk stu-dents, [c] continuous progress monitor-ing at the secondary and subsequenttiers, and Ld) a combination of a prob-lem-solving model and the use of astandard protocol. AH of the sites, how-ever, lacked specific data on fidelity ofimplementation of the interventions andspecific details regarding decision mak-ing on responsiveness to the interven-tions.

    One outcome derived from analyzingthese sites' RTI models was the abilityto characterize the features of an RTImodel thai is successfully implementedin a school setting. In a school with awell-functioning RTI model: (a) stu-dents receive high-quality, research-based instruction from qualified staff intlieir general education setting; (b) gen-eral education staff members assume anactive role in students' assessment inthe curriculum; (c) school staff con-ducts universal screening of academicsand behavior; (d) school staff imple-ments specific, research-based interven-tions to address the students' difficul-ties; (e) school staff conducts continu-ous progress monitoring of student per-formance (i.e., weekly or biweekly) forsecondary and tertiary interventionsand less frequently in general educa-tion; (f) school staff uses progress mon-itoring data and explicit decision rules10 determine interventions' effective-ness and necessary modifications; (g)systematic assessment is made regard-ing the fidelity or integrity with whichinstruction and interventions are imple-mented; and (h) the RTI modelincludes, as required, provisions forreferral for comprehensive evaluation,free appropriate public education, anddue process protections [NationalResearch Center on Learning Dis-abilities, 2006).IDEA Regulirtory GuidanceAs noted, the statutory reference to RTIis brief. In comments responding to theNotice for Proposed Rule Making for theIDEA federal regulations (USED, 2005),RTI ranked among the top-three issuesin the number of comments received

    (USED, 2006). The majority of com-ments spoke to the need for more direc-tion regarding the identification of chil-dren with SLD, the implementation ofRTI, and clarification as to how RTI fitswithin the existing evaluation and pro-cedural safeguards (USED, 2006). InAugust 2006, the IDEA regulatory guid-ance was published. The following sec-tion describes the key issues addressedin the regulations including evaluationfor SLD, RTI definition, parental notice,and LEA request for evaluation. Thisinformation is intended to supplementand not to replace careful study andapplication of IDEA and its regulations.

    In evaluating a child with SLD, thestate criteria must not require the use ofa severe discrepancy between intellectu-al ability and achievement and the cri-teria must permit the use of a processbased on the child's response to scien-tific, research-based intervention. Thesestate criteria must be used by publicagencies in determining whether a childhas an SLD. Certain standards for eval-uation using RTI are presented in theregulations. One aspect that must beexamined when determining the exis-tence of SLD is whether the child ismaking sufficient progress for thechild's age or to meet state-approvedgrade-level standards. Another facet isensuring that underachievement in achild suspected of having a SLD is notdue to the lack of appropriate instruc-tion in reading or math.

    Additionally, the regulations do notdefine RTI but instead state that thereare many RTI models. Accordingly, theregulations are written to accommodatethe many different models that are cur-rently in use. Although the Departmentdoes not mandate or endorse any par-ticular model, the regulations mandatethat states permit the use of a process,based on the child's response to scien-tific, research-based intervention(USED, 2006 300.3O7(a)(2)]. Althoughmany of the specific procedures to beused are not defined in either IDEA orits regulatory guidance, the importanceof timelines and structured communica-tion with parents is emphasized.

    Regarding parental notice, the regu-lations state that the public agency mustpromptly request parental consent to

    evaluate the child to determine if tchild needs special education and reled services and must adhere to the timframes described in 300.301 a300.303. Parent consent must requested if, prior to a referral, a chihas not made adequate progress after appropriate period of time when provied instruction as described in the reglations, or when the child is referred evaluation lUSED, 2006 300.307(cThe regulations recognize that instrutional models vary in terms of the frquency and number of repeated assesments that are required to determinechild's progress; accordingly, states mcreate criteria that take local variatiinto consideration.

    Regarding the comprehensive evaation, the regulations are clear that Ris not a substitute for a comprehensievaluation. A variety of data-gatheriand assessment tools and strategimust be used even if an RTI model hbeen implemented. No single proceducan be relied on as the sole criterion fdetermining eligibility for special eduction services. Each state must develcriteria to determine whether a chihas a disability and RTI can be one coponent of the information review(USED, 2006,46648).Moving Ibwards Large-ScaleImplementaHonAs schools, districts, and states motoward more wide-scale implementatiof RTI, multiple challenges remain. Tgreatest challenge in implementing Ris the limited experience of doing so oa large scale, across all academic areand age levels. Even with these gaps knowledge, however, there is evidensupporting RTI as an improvement ovpast identification models. The Analyof Comments addresses this issue;

    There is an evidence base to sup-port the use of RTI models toidentify children with SLD on awide scale, including young chil-dren and children from minoritybackgrounds. These include sev-eral large-scale implementationsin Iowa (the Heartland model;Tilly, 2002); the Minneapolis pub-lic schools (Marston, 2003); appli-cations of the Screening toEnhance Equitable Placement

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    tSTEEP) model in Mississippi,Louisiana, and Arizona (VanDer-Heyden, Witt, & Gilbertson, inpress); and other examples(NASDE, 2005). While it is truethat much of the research on RTImodels has been conducted in thearea of reading, 80 to 90 percentof children with SLD experiencereading problems. The implemen-tation of RTI in practice, however,has included other domains.(USED, 2005 46647)

    The greatest challenge inimplementing RTI is the

    limited experience ofimplementing it on a largescale, across all academic

    areas and age levels.

    Ideally, large-scale implementationof any new innovation would be pre-ceded by significant research and devel-opment efforts. The reality, however, isthat policy often precedes and drivesresearch and development. In additionto RTI. policy has preceded a large bodyof evidence in the areas of assessment,access to the general curriculum, anddiscipline issues [Danielson, Doolittle, &Bradley, 2005J.

    Given that most students with dis-abilities (93.6%J spend at least part ofeach school day in a general educationclassrooman average of 4.8 hours perday (Wagner & Blackorby, 2002)thegreatest challenge of scating-up RTIcould rest largely in the general educa-tion arena. The preparation of all edu-cators to assist aU students, includingthose with disabilities, in meaningfullyaccessing the general curriculumbecomes a critical component of suc-cessful targe scale imp lem entatio n.Further discussion is also neededregarding implementation of the modelin middle school and high school, theuse of RTI in content areas other thanearly reading, and the role of parents inthe process. Currently, the momentumaround the potential benefits of RTI has

    created a critical mass of professionalswilling to forge ahead despite the unan-swered questions surrounding thedetails of implementation.OSEP is committed to the provisionof technical assistance to assist states inthe implementation of RTI. NRCLD con-tinues to provide information toenhance implementation strategies andsoon will release a resource kit withinformation for implementers and fami-lies. OSEP is also collaborating with(and co-funded) the ComprehensiveCenter on Instructionoverseen by theU.S. Office of Elementary and Secon-dary Ed ucationto embed RTI informa-

    tion and developments within the gen-eral education framework. OSEP alsohas a variety of information available onRTI as part of the recent IDEA Part Bregulation rollout activities that can beaccessed at http://idea.ed.gov. As fur-ther implementation strategies and out-come data accrue, OSEP continues towork with the technical assistance cen-ters, parent training centers, state edu-cational agencies, and other govern-mental offices to ensure that educators,administrators, and parents are wellinformed about RTI.

    Nearly 10 years ago, the professionalorganizations involved in improvingservices for children with SLD elevatedthe discussion of the need to developmore accurate and efficient processesfor the identification of these students toa national level. The 2004 reauthorizedIDEA and guidance in the subsequentregulations, as well as the wealth ofinformation being generated fromNRCLD and other centers on how toproceed in implementing RTI, havehelped create a great opportunity toimprove the identification of, and serv-ices for, children with SLD. Even moreexciting is the current chance to infusestrategies and interventions that tradi-tionally are used only in special educa-tionsuch as progress monitoringinto the day-to-day practice of generaleducation. Success in this venture couldimprove instruction and learning formany children, those with and withoutdisabilities.

    For more information on RTI and th eIDEA federal regulations, please visitThe National Research Center on Learn-ing Disabilities Web site at http://www.NRCLD.org, and the Department's IDEAregulation Web site at h ttp://idea.ed.gov.

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    RCtCfCIKOSBradley, R., & Danielson, L. (2004). Office of

    Special Education Program's LD initiative:A context for inquiry and consensus.Learning Disability Quarterly, 27(4),186-188.

    Bradley. R., Danielson, L., & Doolittle, J.(2005). Response to Intervention. Journalol Learning Disabilities. 38(6), 485-486.

    Bradley, R., Danielson, L., & Hallahan, D.(2002). Identification of learning disabili-ties: Research to practice. Mahwah, NJ:Lawrence Eribdum.

    Cortiella, C. (2006). A parent's guide toresponse-lo-intervention [Web site|.Retrieved January 12, 2007, from http://w w w . n c l d . o r g / i in a g e s / s t o r i e s /down loads/parent_center/rti_fmal.pdf

    Danielson, L.. Doolittle, J., & Bradley. R.(2005). Past accomplishments and futurechallenges. Learning Disability Quarterly,2[2), 1. 7-1. 9.

    Individuals Wilh Disabilities Education Actof 2004 (IDEA 2004), Public Law 108-446,108th Congress. Dec. 3, 2004. Availablethrough http://idea.ed.gov/explore/home(accessed Feb. 14, 2007).

    National Joint Committee on LearningDisabilities (NJCLD). (1997). As ciled inU.S. Department of Education, "Assist-ance to Slates for the Education of Child-ren With Disabilities, Preschool Grants forChildren With Disabilities, and EarlyIntervention Program for Infants and Tod-

    dlers With Disabilities: Proposed Rule," 34CFR 300, 301, and 303, Federal Register62: 204 (Oct. 22. 1997). Available at:ht tp: / /www.ed.gov/ legis la t ion/FedRegister/propru!e/l 997-4/102297a. him!(accessed March 5, 2007).

    National Research Center on LearningDisabilities. (2006). Core concepts of RTI[Web site]. Retrieved January 12, 2007,from http://www.nrcld.org/research/rti/concepls.shtm!

    U.S. Department of Education (USED).(2005). "Assistance to States for Ihe Edu-cation of Children With Disabilities andPreschool Grants for Children With Dis-abilities; Proposed Rule," .14 CFR Parts300, 301. and 304. Federal Register 70:118(June 21 , 2005): 35781-35892. Available at:ht tp/ /www. ed.gov/ legis la t ion/FedRegister/proprule/2005-2/062105a.httnl(accessed February 14. 2007).

    U.S. Department of Education (USED)(2006). "Assistance to States for theEducation of Children With Disabilitiesand Preschool Grants for Children WithDisabilities: Final Rule." .34 CFR Parts 300and 301, Federal Register 71:156 (Aug. 14.2006): 46540-46845. Available at:http://www.idea.ed.gov/download/final-regulations.pdr (accessed February 14.2007).

    Wagner, R.. & Blackorby. J. (2002)- Disabilityprofiles of elementary and middle schoolstudents with disabilities: Special Educa-

    tion Elementary Longitudinal Stu(SEELS). Palo Alto. GA: SRI Internation

    Ysseldyke. J. (2002). Response to "Learnidisabilities: Historical perspective.*;." In Bradley, L. Danielson, & D. P. Hallah(Eds.), Identification of learning disabities: Research to practice (pp. 89-9Mahwah. NJ: Lawrence Erlbaum.

    Renee Bradley (CEC VA Federation). SpecAssistant to the Director: Louis Daniels(CEC VA Federation), Director: and JenniDooHttle, Education Program SpecialiResearch to Practice Division, Office of SpeEducation Programs. U.S. Department Education, Washington. DC.Opinions expressed herein are those of tauthors and do not necessarily reflect tposition or policies of the U.S. Office Special Education Programs or the UDepartment of Education, and no officendorsement by the government should inferred.Address correspondence to Renee BradleOffice of Special Education Programs. UDepartment of Education, Washington. D20208 (e-mail: [email protected]}.TEACHING Exceptional Children, Vol. .No. 5. pp. 8-12.Copyright 2007 CEC.

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