1. Response to Intervention www.interventioncentral.org RTI: An Overview for Administrators Jim Wright www.interventioncentral.org

2. Response to Intervention www.interventioncentral.org RTI: Overview for Administrators: Agenda… 1.RTI: An Introduction 2.Tiers 1, 2 & 3: Description 3.Evaluating a Student’s ‘Non-Responder’ Status: A Comprehensive Checklist 4.Review of RTI Web Resources to Support Schools

3. Response to Intervention www.interventioncentral.org 3 “The quality of a school as a learning community can be measured by how effectively it addresses the needs of struggling students.” --Wright (2005) Source: Wright, J. (2005, Summer). Five interventions that work. NAESP Leadership Compass, 2(4) pp.1,6.

4. Response to Intervention www.interventioncentral.org 4 School Instructional Time: The Irreplaceable Resource “In the average school system, there are 330 minutes in the instructional day, 1,650 minutes in the instructional week, and 56,700 minutes in the instructional year. Except in unusual circumstances, these are the only minutes we have to provide effective services for students. The number of years we have to apply these minutes is fixed. Therefore, each minute counts and schools cannot afford to support inefficient models of service delivery.” p. 177 Source: Batsche, G. M., Castillo, J. M., Dixon, D. N., & Forde, S. (2008). Best practices in problem analysis. In A. Thomas & J. Grimes (Eds.), Best practices in school psychology V (pp. 177-193).

5. Response to Intervention www.interventioncentral.org 5 RTI Assumption: Struggling Students Are ‘Typical’ Until Proven Otherwise… RTI logic assumes that: –A student who begins to struggle in general education is typical, and that –It is general education’s responsibility to find the instructional strategies that will unlock the student’s learning potential Only when the student shows through well-documented interventions that he or she has ‘failed to respond to intervention’ does RTI begin to investigate the possibility that the student may have a learning disability or other special education condition.

6. Response to Intervention www.interventioncentral.org 6 Essential Elements of RTI (Fairbanks, Sugai, Guardino, & Lathrop, 2007) 1.A “continuum of evidence-based services available to all students" that range from universal to highly individualized & intensive 2.“Decision points to determine if students are performing significantly below the level of their peers in academic and social behavior domains" 3.“Ongoing monitoring of student progress" 4.“Employment of more intensive or different interventions when students do not improve in response" to lesser interventions 5.“Evaluation for special education services if students do not respond to intervention instruction" Source: Fairbanks, S., Sugai, G., Guardino, S., & Lathrop, M. (2007). Response to intervention: Examining classroom behavior support in second grade. Exceptional Children, 73, p. 289.

7. Response to Intervention www.interventioncentral.org NYSED RTI Guidance Memo: April 2008 Source: DeLorenzo, J. P., & Stevens, J. C. (April 2008). Implementation of response to intervention programs. [Memorandum issued by New York State Education Department]. Retrieved November 25, 2008, from http://www.vesid.nysed.gov/specialed/publications/policy/RTI.htm

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9. Response to Intervention www.interventioncentral.org The Regents policy framework for RtI: 4.Authorizes the use of RtI in the State's criteria to determine learning disabilities (LD) and requires, effective July 1, 2012, that all school districts have an RtI program in place as part of the process to determine if a student in grades K-4 is a student with a learning disability in the area of reading. “ Effective on or after July 1, 2012, a school district shall not use the severe discrepancy criteria to determine that a student in kindergarten through grade four has a learning disability in the area of reading.” [8 NYCRR section 200.4(j)] 9 Source: DeLorenzo, J. P., & Stevens, J. C. (April 2008). Implementation of response to intervention programs. [Memorandum issued by New York State Education Department]. Retrieved November 25, 2008, from http://www.vesid.nysed.gov/specialed/publications/policy/RTI.htm

10. Response to Intervention www.interventioncentral.org 10 RTI ‘Pyramid of Interventions’ Tier 1 Tier 2 Tier 3 Tier 1: Universal interventions. Available to all students in a classroom or school. Can consist of whole-group or individual strategies or supports. Tier 2 Individualized interventions. Subset of students receive interventions targeting specific needs. Tier 3: Intensive interventions. Students who are ‘non- responders’ to Tiers 1 & 2 are referred to the RTI Team for more intensive interventions.

11. Response to Intervention www.interventioncentral.org 11 Source: New York State Education Department. (October 2010). Response to Intervention: Guidance for New York State School Districts. Retrieved November 10, 2010, from http://www.p12.nysed.gov/specialed/RTI/guidance-oct10.pdf; p. 12

12. Response to Intervention www.interventioncentral.org 12 Tier 1 Core Instruction Tier I core instruction: Is universal—available to all students. Can be delivered within classrooms or throughout the school. Is an ongoing process of developing strong classroom instructional practices to reach the largest number of struggling learners. All children have access to Tier 1 instruction/interventions. Teachers have the capability to use those strategies without requiring outside assistance. Tier 1 instruction encompasses: The school’s core curriculum. Al published or teacher-made materials used to deliver that curriculum. Teacher use of ‘whole-group’ teaching & management strategies. Tier I instruction addresses this question: Are strong classroom instructional strategies sufficient to help the student to achieve academic success?

13. Response to Intervention www.interventioncentral.org 13 Tier I (Classroom) Intervention Tier 1 intervention: Targets ‘red flag’ students who are not successful with core instruction alone. Uses ‘evidence-based’ strategies to address student academic or behavioral concerns. Must be feasible to implement given the resources available in the classroom. Tier I intervention addresses the question: Does the student make adequate progress when the instructor uses specific academic or behavioral strategies matched to the presenting concern?

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15. Response to Intervention www.interventioncentral.org 15 Complementary RTI Models: Standard Treatment & Problem-Solving Protocols “The two most commonly used RTI approaches are (1) standard treatment and (2) problem- solving protocol. While these two approaches to RTI are sometimes described as being very different from each other, they actually have several common elements, and both fit within a problem-solving framework. In practice, many schools and districts combine or blend aspects of the two approaches to fit their needs.” Source: Duffy, H. (August 2007). Meeting the needs of significantly struggling learners in high school. Washington, DC: National High School Center. Retrieved from http://www.betterhighschools.org/pubs/ p. 5

16. Response to Intervention www.interventioncentral.org 16 RTI Interventions: Standard-Treatment vs. Problem-Solving There are two different vehicles that schools can use to deliver RTI interventions: Standard-Protocol (Standalone Intervention). Programs based on scientifically valid instructional practices (‘standard protocol’) are created to address frequent student referral concerns. These services are provided outside of the classroom. A middle school, for example, may set up a structured math-tutoring program staffed by adult volunteer tutors to provide assistance to students with limited math skills. Students referred for a Tier II math intervention would be placed in this tutoring program. An advantage of the standard- protocol approach is that it is efficient and consistent: large numbers of students can be put into these group interventions to receive a highly standardized intervention. However, standard group intervention protocols often cannot be individualized easily to accommodate a specific student’s unique needs. Problem-solving (Classroom-Based Intervention). Individualized research-based interventions match the profile of a particular student’s strengths and limitations. The classroom teacher often has a large role in carrying out these interventions. A plus of the problem-solving approach is that the intervention can be customized to the student’s needs. However, developing intervention plans for individual students can be time-consuming.

17. Response to Intervention www.interventioncentral.org 17 Source: New York State Education Department. (October 2010). Response to Intervention: Guidance for New York State School Districts. Retrieved November 10, 2010, from http://www.p12.nysed.gov/specialed/RTI/guidance-oct10.pdf; p. 13

18. Response to Intervention www.interventioncentral.org 18 Tier 2: Supplemental (Group-Based) Interventions (Standard Treatment Protocol) Tier 2 interventions are typically delivered in small-group format. About 15% of students in the typical school will require Tier 2/supplemental intervention support. Group size for Tier 2 interventions is limited to 4-7 students. Students placed in Tier 2 interventions should have a shared profile of intervention need. Programs or practices used in Tier 2 interventions should be ‘evidence-based’. The progress of students in Tier 2 interventions are monitored at least 2 times per month. Source: Burns, M. K., & Gibbons, K. A. (2008). Implementing response-to-intervention in elementary and secondary schools. Routledge: New York.

19. Response to Intervention www.interventioncentral.org 19 Source: New York State Education Department. (October 2010). Response to Intervention: Guidance for New York State School Districts. Retrieved November 10, 2010, from http://www.p12.nysed.gov/specialed/RTI/guidance-oct10.pdf; p. 14

20. Response to Intervention www.interventioncentral.org 20 Tier 3: Intensive Individualized Interventions (Problem-Solving Protocol) Tier 3 interventions are the most intensive offered in a school setting. Students qualify for Tier 3 interventions because: –they are found to have a large skill gap when compared to their class or grade peers; and/or –They did not respond to interventions provided previously at Tiers 1 & 2. Tier 3 interventions are provided daily for sessions of 30 minutes or more. The student-teacher ratio is flexible but should allow the student to receive intensive, individualized instruction. The reading progress of students in Tier 3 interventions is monitored at least weekly. Source: Burns, M. K., & Gibbons, K. A. (2008). Implementing response-to-intervention in elementary and secondary schools. Routledge: New York.

21. Response to Intervention www.interventioncentral.org The Key Role of Classroom Teachers in RTI: 6 Steps Jim Wright www.interventioncentral.org

22. Response to Intervention www.interventioncentral.org 22 RTI ‘Pyramid of Interventions’ Tier 1 Tier 2 Tier 3 Tier 1: Universal interventions. Available to all students in a classroom or school. Can consist of whole-group or individual strategies or supports. Tier 2 Individualized interventions. Subset of students receive interventions targeting specific needs. Tier 3: Intensive interventions. Students who are ‘non- responders’ to Tiers 1 & 2 are referred to the RTI Team for more intensive interventions.

23. Response to Intervention www.interventioncentral.org 23 Focus on School Factors That We Can Control “Some factors in students’ lives (such as family divorce, moving frequently, drug use, and poor teaching) lower the probability that these students will learn and/or get along with others. These are often referred to as risk factors…Risk factors do not assure student failure. Risk factors simply make the odds of failure greater. Aligning assessment and instruction allows teachers…to introduce new factors into the student’s life that raise the probability of learning. These are often called protective factors since they protect against the risks associated with risk factors…The use of protective factors to raise the probability of learning is often referred to as resilience.” Source: Hosp, J. L. (2008). Best practices in aligning academic assessment with instruction. In A. Thomas & J. Grimes (Eds.), Best practices in school psychology V (pp.363-376). Bethesda, MD: National Association of School Psychologists.

24. Response to Intervention www.interventioncentral.org The Key Role of Classroom Teachers in RTI: 6 Steps 1.The teacher defines the student academic or behavioral problem clearly. 2.The teacher decides on the best explanation for why the problem is occurring. 3.The teacher selects ‘evidence-based’ interventions. 4.The teacher documents the student’s Tier 1 intervention plan. 5.The teacher monitors the student’s response (progress) to the intervention plan. 6.The teacher knows what the next steps are when a student fails to make adequate progress with Tier 1 interventions alone. 24

25. Response to Intervention www.interventioncentral.org 25 The Key Role of Classroom Teachers in RTI… 1. The teacher defines the student academic or behavior problem in clear, specific, measurable terms.

26. Response to Intervention www.interventioncentral.org Defining Academic or Behavioral Problems Describe the student problem to provide a meaningful instructional context. The teacher is more likely to select an effective intervention to help a struggling student if the student problem is first clearly defined and put into a meaningful context. This expanded definition includes information about the conditions under which the academic problem is observed and typical or expected level of performance. – Conditions. Describe the environmental conditions or task demands in place when the academic problem is observed. – Problem Description. Describe the actual observable academic behavior in which the student is engaged. Include rate, accuracy, or other quantitative information of student performance. – Typical or Expected Level of Performance. Provide a typical or expected performance criterion for this skill or behavior. Typical or expected academic performance can be calculated using a variety of sources, 26

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28. Response to Intervention www.interventioncentral.org 28 The Key Role of Classroom Teachers in RTI… 2. The teacher decides on the best explanation for what is causing the student problem.

29. Response to Intervention www.interventioncentral.org 29 Big Ideas: The Four Stages of Learning Can Be Summed Up in the ‘Instructional Hierarchy’ (Haring et al., 1978) Student learning can be thought of as a multi-stage process. The universal stages of learning include: Acquisition: The student is just acquiring the skill. Fluency: The student can perform the skill but must make that skill ‘automatic’. Generalization: The student must perform the skill across situations or settings. Adaptation: The student confronts novel task demands that require that the student adapt a current skill to meet new requirements. Source: Haring, N.G., Lovitt, T.C., Eaton, M.D., & Hansen, C.L. (1978). The fourth R: Research in the classroom. Columbus, OH: Charles E. Merrill Publishing Co.

30. Response to Intervention www.interventioncentral.org 30 The Key Role of Classroom Teachers in RTI… 3. The teacher selects one or more ‘evidence- based’ interventions to address the student problem.

31. Response to Intervention www.interventioncentral.org A Sampling of Intervention Websites The What Works Clearinghouse has a series of free practice guides that detail best recommended practices for promoting adolescent literacy, study and organizational skills and more. http://ies.ed.gov/ncee/wwc/publications/ practiceguides/ 31

32. Response to Intervention www.interventioncentral.org A Sampling of Intervention Websites Intervention Central has a collection of research-based interventions for academic and behavioral concerns http://www.interventioncentral.org 32

33. Response to Intervention www.interventioncentral.org 33 The Key Role of Classroom Teachers in RTI… 4. The teacher documents the student’s Tier 1 (classroom) intervention plan.

34. Response to Intervention www.interventioncentral.org 34 Interventions: Potential ‘Fatal Flaws’ Any intervention must include 4 essential elements. The absence of any one of the elements would be considered a ‘fatal flaw’ (Witt, VanDerHeyden & Gilbertson, 2004) that blocks the school from drawing meaningful conclusions from the student’s response to the intervention: 1.Clearly defined problem. The student’s target concern is stated in specific, observable, measureable terms. This ‘problem identification statement’ is the most important step of the problem-solving model (Bergan, 1995), as a clearly defined problem allows the teacher or RTI Team to select a well-matched intervention to address it. 2.Baseline data. The teacher or RTI Team measures the student’s academic skills in the target concern (e.g., reading fluency, math computation) prior to beginning the intervention. Baseline data becomes the point of comparison throughout the intervention to help the school to determine whether that intervention is effective. 3.Performance goal. The teacher or RTI Team sets a specific, data-based goal for student improvement during the intervention and a checkpoint date by which the goal should be attained. 4.Progress-monitoring plan. The teacher or RTI Team collects student data regularly to determine whether the student is on-track to reach the performance goal. Source: Witt, J. C., VanDerHeyden, A. M., & Gilbertson, D. (2004). Troubleshooting behavioral interventions. A systematic process for finding and eliminating problems. School Psychology Review, 33, 363-383.

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36. Response to Intervention www.interventioncentral.org 36 The Key Role of Classroom Teachers in RTI… 5. The teacher monitors the students response (progress) to the intervention plan.

37. Response to Intervention www.interventioncentral.org Classroom Methods of Data Collection Existing records Global skills checklist Rating scales Behavioral frequency count Behavioral log Student work samples Work performance logs Timed assessments (e.g., Curriculum-Based Measurement)

38. Response to Intervention www.interventioncentral.org Example of Classroom Progress-Monitoring Tool: Global Skills Checklists Description: The teacher selects a global skill. The teacher then breaks that global skill down into specific, observable ‘subskills’. Each subskill can be verified as ‘done’ or ‘not done’. 38

39. Response to Intervention www.interventioncentral.org Skills Checklists: Example The teacher selects the global skill ‘organizational skills’. That global skill is defined as having the following components, each of which can be observed:  arriving to class on time;  bringing work materials to class;  following teacher directions in a timely manner;  knowing how to request teacher assistance when needed;  having an uncluttered desk with only essential work materials. 39

40. Response to Intervention www.interventioncentral.org 40 The Key Role of Classroom Teachers in RTI… 6. The teacher knows what the next steps are when a student fails to make adequate progress with Tier 1 interventions alone.

41. Response to Intervention www.interventioncentral.org Tier 1: Decision Rules The classroom teacher knows that Tier 1 (classroom) interventions alone are not sufficient for the struggling student when: The student problem is clearly defined. Appropriate evidence-based interventions have been selected that match the student’s presenting concern(s). The intervention plan has been tried for an adequate amount of time (e.g., 4-8 instructional weeks). Student baseline performance is measured, a goal is calculated, and progress-monitoring data is collected during the intervention. The student has not significantly closed the gap with peers despite the classroom intervention plan. 41

42. Response to Intervention www.interventioncentral.org 42 Activity: What Questions Do You Have About RTI? At your tables, discuss the content covered so far in this workshop. As educational leaders, what questions do you still have about RTI?

43. Response to Intervention www.interventioncentral.org RTI Lab: Creating District Decision Rules for Analyzing RTI Data to Determine LD Eligibility Jim Wright www.interventioncentral.org

44. Response to Intervention www.interventioncentral.org Special Education Eligibility & RTI: Establishing Confidence at Every Link Special Education Eligibility Teams review the CUMULATIVE RTI information collected in general education (‘intervention audit’). If that Team lacks confidence in any one of the links in the RTI chain, it will be difficult to identify the student as an RTI ‘non-responder’ The goal of this workshop is to help schools to identify each link in the RTI chain and to know how to measure the quality of that link. 44

45. Response to Intervention www.interventioncentral.org RTI & Special Education Eligibility

46. Response to Intervention www.interventioncentral.org 46 RTI ‘Pyramid of Interventions’ Tier 1 Tier 2 Tier 3 Tier 1: Universal interventions. Available to all students in a classroom or school. Can consist of whole-group or individual strategies or supports. Tier 2 Individualized interventions. Subset of students receive interventions targeting specific needs. Tier 3: Intensive interventions. Students who are ‘non- responders’ to Tiers 1 & 2 are referred to the RTI Team for more intensive interventions.

47. Response to Intervention www.interventioncentral.org 47 Target Student Discrepancy 1: Skill Gap (Current Performance Level) Avg Classroom Academic Performance Level ‘Dual-Discrepancy’: RTI Model of Learning Disability (Fuchs 2003) Discrepancy 2: Gap in Rate of Learning (‘Slope of Improvement’)

48. Response to Intervention www.interventioncentral.org Current NYS Definition of ‘Learning Disabled’ 48

49. Response to Intervention www.interventioncentral.org RTI Information: What It Does and Doesn’t Do The primary purpose for the special education eligibility team to evaluate general-education RTI information is to rule out instructional explanations for the struggling student’s academic concerns. RTI information does not in and of itself provide detailed information to allow schools to draw conclusions about a student’s possible neurological differences that make up the construct ‘learning disabilities’. Therefore, RTI information allows for a rule-out (the learning problem resides within the student, not the classroom) but does not in and of itself provide positive evidence of a learning disability. 49

50. Response to Intervention www.interventioncentral.org Using RTI Information to Identify the ‘Non- Responding’ Student: Goodbye, Gate As a special education eligibility team adopts a process for evaluating a student’s RTI information as a ‘non-responder’ to intervention as part of an evaluation for learning disabilities, the team will discover that there is no longer a single ‘actuarial number’ or gate to determine ‘risk’ of LD in the manner of a test score discrepancy analysis. Therefore, the special education eligibility team must have confidence in the quality of the intervention and assessment programs available to the struggling student in the general education setting. Today’s workshop is about increasing that level of confidence. 50

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52. Response to Intervention www.interventioncentral.org Special Education Eligibility Team & RTI Information: Recommendations Create guidelines for general education to use to determine whether a student is a ‘non- responder’ under RTI. NOTE: Such guidelines are for the sole use of general education and should not be interpreted as RTI ‘special education eligibility criteria’. Create a checklist for schools to collect, collate, and ‘package’ RTI information for presentation to the Special Education Eligibility Team. 52

53. Response to Intervention www.interventioncentral.org Special Education Eligibility Team & RTI Information: Recommendations (Cont.) RTI information should be reviewed prior to the initial LD eligibility meeting. If there is questionable information, the Special Education Eligibility Team should contact the school to clarify questions. At the actual eligibility meeting, any concerns or questions about the RTI information should be framed in neutral terms and tied to the dual discrepancy RTI LD model. Whenever possible, schools should not feel ‘blamed’ for shortcomings of RTI information and should feel that the identification process is transparent. 53

54. Response to Intervention www.interventioncentral.org Special Education Eligibility Team & RTI Information: Recommendations (Cont.) It should be an expectation that at eligibility meetings: The Special Education Eligibility Team can ask for clarification of any building RTI information presented The Team is able to articulate how it interprets information and why it reaches its decision. 54

55. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: An RTI Checklist Interventions: Evidence-Based & Implemented With Integrity Tier 1: High-Quality Core Instruction Tier 1: Classroom Intervention Tier 2 & 3 Interventions: Minimum Number & Length Tier 2 & 3 Interventions: Essential Elements Tier 1, 2, & 3 Interventions: Intervention Integrity 55

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61. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: Activity 61 At your table: Review these ‘RTI Non-Responder’ elements. Tier 1: High-Quality Core Instruction Tier 1: Classroom Intervention Tier 2 & 3 Interventions: Minimum Number & Length Tier 2 & 3 Interventions: Essential Elements Tier 1, 2, & 3 Interventions: Intervention Integrity Select the element that you see as your school or district’s greatest challenge. Brainstorm ideas to positively address that challenge.

62. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: An RTI Checklist Academic Screenings: General Outcome Measures and Skill-Based Measures Selection of Academic Screening Measures Local Norms Collected via Gradewide Academic Screenings at Least 3 Times Per Year 62

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65. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: An RTI Checklist Dual Discrepancy Cut-Offs: Academic Skill Level and Student Rate of Improvement Cut-point Established to Define ‘Severely Discrepant’ Academic Performance Cut-Off Criterion Selected to Define Discrepant Slope 65

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68. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: An RTI Checklist Data Collection Use of Both ‘Off-Level’ and Enrolled Grade-Level Benchmarks & Progress-Monitoring Measures to Assess Student Skills and Growth Student Baseline Calculated Student Goal Calculated Regular Progress-Monitoring Conducted 68

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73. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: An RTI Checklist Application of RTI Decision Rules to a Particular Student Case Despite the Tier 2/3 Interventions Attempted, the Student’s Skills Continue to Fall Below the Boundary of ‘Severely Discrepant’ Academic Performance Despite the Tier 2/3 Interventions Attempted, the Student’s Rate of Improvement (Slope) Continues to Be Discrepant 73

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75. Response to Intervention www.interventioncentral.org Evaluating a Student’s ‘Non-Responder’ Status: Activity 75 At your table: Discuss how your school or district may use the document Evaluating a Student’s ‘Non- Responder’ Status: An RTI Checklist to: increase compliance at every link in the ‘RTI chain’ develop specific decision rules for determining whether a student referred for a possible Learning Disability is a ‘non-responder’ to intervention Be prepared to share the main points of your discussion with the large group.

76. Response to Intervention www.interventioncentral.org RTI & Special Education Eligibility: ‘Challenge’ Scenarios Jim Wright www.interventioncentral.org

77. Response to Intervention www.interventioncentral.org RTI & Special Education Eligibility: ‘Challenge’ Scenarios The school presents clear information suggesting that the student has not responded adequately to general- education reading interventions. The school believes that the student should be designated Learning Disabled. In your review of records, however, you note that the student passed the most state ELA test. How might you respond to this issue at the meeting? 77

78. Response to Intervention www.interventioncentral.org RTI & Special Education Eligibility: ‘Challenge’ Scenarios When information is presented from the school on the student’s response to a series of math intervention programs, you see that they have tried 3 interventions at Tiers 2 and 3. However, there is little information about the second of the 3 interventions, including what research-based strategies were used or what progress- monitoring data were collected. The intervention is instead described as ‘the student saw the math intervention teacher for 30 minutes 3 times per week.” How might you respond to this issue at the meeting? 78

79. Response to Intervention www.interventioncentral.org RTI & Special Education Eligibility: ‘Challenge’ Scenarios A student is referred to Special Education because she has apparently failed to respond adequately the school’s Tier 2 and 3 interventions. As you review the student’s RTI information, you realize that the student fell within the average range on the external reading fluency performance norms, even though the classroom teacher has made an emphatic case that the student has severely limited reading skills in the classroom. How might you respond to this issue at the meeting? 79