TECHNICAL ASSISTANCE TO SCHOOL DISTRICTS Identification of Students with Learning Disabilities under the IDEA 2004 Oregon Response to Intervention Office of Student Learning & Partnerships September 2005 OREGON DEPARTMENT OF EDUCATION Public Service Building 255 Capitol Street NE Salem, Oregon 97310-0203 Phone: (503) 378-3569 www.ode.state.or.us This paper could not have been developed without the assistance of the special education staff from Tigard-Tualatin School District. The Oregon Department of Education appreciates their willingness to share their skills and knowledge to benefit Oregon students with disabilities and their families. It is the policy of the State Board of Education and a priority of the Oregon Department of Education that there will be no discrimination or harassment on the grounds of race, color, sex, marital status, religion, national origin, age or disability in any educational programs, activities or employment. Persons having questions about equal opportunity and nondiscrimination should contact the State Superintendent of Public Instruction at the Oregon Department of Education. Identification of Students with Learning Disabilities under the IDEA 2004 Oregon Response to Intervention This report is posted on the ODE website at: http://www.ode.state.or.us/search/results/?id=319. (Effective September 28, 2005) The Oregon Department of Education hereby gives permission to copy any or all of this document for educational purposes. OrRTI Guidance, September 2005 i OrPTI Guidance, September 2005 ii OrRTI Guidance Table of Contents Page Introduction......................................................................................................... 1 Section One, Response to Intervention ............................................................ 5 Section Two, Implementing Response to Intervention (RTI) ........................ 17 Section Three, Perspectives on Evaluation Models ...................................... 39 Appendix References .............................................................................................. 45 Response to Intervention Readiness Checklist ........................................ 51 OrRTI Guidance, September 2005 iii OrPTI Guidance, September 2005 iv Introduction Every day Oregon educators make decisions about children that are of life long importance. Among the most profound of these is the conclusion that a child’s educational struggles are the result of a disability. Educators engage in this difficult task because they know that, despite the dangers inherent in labeling students, important benefits may follow. When the decision is accurate, it can help parents and children understand the source of difficulties. It opens the door to resources, assistance, and accommodations. Deciding a child does not have a disability is equally important. That conclusion says to general educators that they can effectively educate the student. It tells parents and students that success is attainable through hard work, practice, and engaged instruction, without special education services. It is critical that schools make these decisions based on the best information possible. For the majority of children in special education, those identified as having a learning disability (LD), this decision has been made in a climate of uncertainty. For decades the field of learning disabilities has struggled with identification issues both in practice and in the law. However, with the 2004 reauthorization of the Individuals with Disabilities Education Act (IDEA 2004), the climate is changing. When IDEA was reauthorized in 1997, the U.S. Department of Education Office of Special Education Programs (OSEP) began a process to “carefully review research findings, expert opinion, and practical knowledge … to determine whether changes should be proposed to the procedures for evaluating children suspected of having a specific learning disability” (Federal Register, 1999, p. 12541). This review resulted in a “Learning Disabilities Summit.” At this summit, a series of white papers presented relevant developments in the LD field and provided empirical validation for the use of alternatives to traditional discrepancy models. Following the summit, a series of meetings was conducted to gain consensus in the field regarding issues around LD. The following are consensus statements from the 2002 Learning Disabilities Roundtable report that apply to LD identification and were influential in the 2004 reauthorization process: Identification should include a student-centered, comprehensive evaluation and problem solving approach that ensures students who have a specific learning disability are efficiently identified. Decisions regarding eligibility for special education services must draw from information collected from a comprehensive individual evaluation using multiple methods and sources of relevant information. Decisions on eligibility must be made through an interdisciplinary team, using informed clinical judgment, directed by relevant data, and based on student needs and strengths. OrRTI Guidance, September 2005 1 The ability-achievement discrepancy formula should not be used for determining eligibility. Regular education must assume active responsibility for delivery of high quality instruction, research-based interventions, and prompt identification of individuals at risk while collaborating with special education and related services personnel. Based on an individualized evaluation and continuous progress monitoring, a student who has been identified as having a specific learning disability may need different levels of special education and related services under IDEA at various times during the school experience. (Source: Specific Learning Disabilities: Finding Common Ground; pp. 29-30) IDEA 2004 represents consensus on at least three points regarding LD identification. These points are: (1) the field should move away from the use of aptitude achievement discrepancy models, (2) there needs to be rapid development of alternative methods of identifying students with learning disabilities, and (3) a response to intervention (RTI) model is the most credible available method to replace discrepancy. RTI systematizes the clinical judgment, problem solving, and regular education interventions recommended in the consensus statements above. In RTI, students are provided with carefully designed interventions that are research based, and their response to those interventions is carefully tracked. This information is analyzed and used as one component in determining whether a child has a learning disability. IDEA 2004 includes two important innovations designed to promote change: 1. States may not require school districts to use a severe discrepancy formula in eligibility determination, and 2. Districts may use an alternative process, including a “response to intervention” (RTI) method described in IDEA 2004, as part of eligibility decisions. This document provides information to assist school districts in designing and adopting an RTI approach that best fits the district, is technically sound, and is sustainable. It also reviews current information regarding the use of other evaluation approaches. Whatever model the district uses to implement RTI, such an adoption will affect more than a district’s special education and evaluation departments. RTI requires a way of thinking about instruction, academic achievement, and individual differences that makes it impossible to implement without fully involving general education. It is important that practitioners know why the authors of IDEA 2004 decided to include an alternative to the discrepancy approach. Adopting an alternative OrPTI Guidance, September 2005 2 requires that individuals release long held beliefs and practices and involves substantial effort and resources. Federal requirements call for states to adopt criteria for LD eligibility that districts will be required to use. This paper will provide a basis for Oregon’s criteria and a better understanding of the basis for the criteria for relevant stakeholders. The development and implementation of an RTI model has been identified as an area of focus in Oregon’s System Performance Review & Improvement system (SPR&I). This paper contains three sections: “Response to Intervention,” “Implementing Response to Intervention,” and “Perspectives on Evaluation Models.” “Response to Intervention” provides detail about various models that have been proposed, described, and implemented and strengths and challenges inherent in each. “Implementing Response to Intervention” is a practical guide to developing and sustaining RTI in a school district. “Perspectives on Evaluation Models” reviews background information regarding research in discrepancy and processing models of LD evaluation. OrPTI Guidance, September 2005 3 OrPTI Guidance, September 2005 4 Section One Response to Intervention IDEA 2004 allows the use of a student’s “response to scientific, research-based intervention” (20 U.S.C 1414 (B)(6)(A)) as part of an evaluation. Response to intervention (RTI) functions as an alternative for learning disability (LD) evaluations within the general evaluation requirements of IDEA 2004. The statute continues to include requirements that apply to all disability categories, such as the use of validated, non biased methods, and evaluation in all suspected areas of difficulty. IDEA 2004 adds a new concept in eligibility that prohibits children from being found eligible for special education if they have not received instruction in reading that includes the five essential components of reading instruction identified by the Reading First Program. These requirements are those recognized by the National Reading Panel: phonemic awareness, phonics, reading fluency (including oral reading skills), vocabulary development, and reading comprehension strategies. RTI is included under this general umbrella. By using RTI, it is possible to identify students early, reduce referral bias, and test various theories for why a child is failing. It was included in the law specifically to offer an alternative to discrepancy models. RTI is not a new approach. It is recognizable under other names such as dynamic assessment, diagnostic teaching, and precision teaching. Those terms, however, have been applied to approaches used to maximize student progress through sensitive measurement of the effects of instruction. RTI applies similar methods to draw conclusions and make LD classification decisions about students. The underlying assumption is that using RTI will identify children whose intrinsic difficulties make them the most difficult to teach. Engaging a student in a dynamic process like RTI provides an opportunity to assess various hypotheses about the causes of a child’s difficulties, such as motivation or constitutional factors like attention. Capacities Required to Adopt RTI Several organizational approaches are available for implementing RTI. These models generally encompass the following four system requirements (Gresham, 2002 Vaughn, 2002): 1. Measurement of academic growth 2. Use of validated interventions 3. Capability of distinguishing between: a. Performance deficits and skill deficits and b. Instructional problems and individual learning problems 4. Ability to determine the effects of interventions and make decisions about cutoff criteria OrPTI Guidance, September 2005 5 These requirements imply both technical and practical capacity that must be considered when an RTI system is developed or adopted. Measurement of Academic Growth Fuchs and Fuchs (1998) introduced the important concept that a student, in order to be considered to have a learning disability, must be dually discrepant. It has been demonstrated that, in order for a student to be reliably classified as having LD, low achievement must be accompanied by slow progress. Using low achievement alone results in group membership that will change substantially over time, with students moving into and out of the group. (Francis et al., 2005). RTI decisions must be made both on the basis of a student’s relative low achievement and on the student’s slow slope of progress. This criterion can be met by use of a well documented approach referred to as curriculum based measurement (Fuchs and Fuchs, 1998). Curriculum based measurement uses “critical indicators” of growth such as oral reading fluency, correct word sequences written, and rate of correct calculations. These measures may be normed on a local sample (Shin, 1988) or on the results of large scale studies. Alternatively, typical peers may be sampled as a direct comparison group during the assessment phase (Fuchs and Fuchs, 1998). CBMs have been established as valid, easy to use, and economical. They can also be used as frequently as daily without threatening their sensitivity. To aid in the early identification of students who are not progressing as expected, Good and Kaminski (Good and Kaminski, 1996) have developed a number of “indicators” of early literacy development as predictors of later reading proficiency. These measures, included in the Dynamic Indicators of Basic Early Literacy Skills (DIBELS), provide a tool to overcome the important challenge of early identification of children with potential reading problems. The DIBELS system allows for careful tracking of students on the development of early skills related to phonological awareness, alphabetic understanding, and fluency. The DIBELS system includes a series of benchmarks that assist in the “sorting” of students into tiered groups that have increasing levels of risk. A further benefit of using the DIBELS system is that oral reading fluency measures extend through sixth grade and provide normative data to thousands of school districts in the United States. The DIBELS measures are provided to Oregon schools at no cost through the Oregon Reading First Project. Further information about DIBELS may be found at http://dibels.uoregon.edu/techreports. It should be noted that RTI research and model implementation generally focuses on elementary aged children. The measures that are available are most appropriately used with younger students and, as students mature, factors such OrPTI Guidance, September 2005 6 as motivation and behavior make interpretation of students’ performance increasingly complex. This is true of traditional testing paradigms as well. RTI models frequently combine response to intervention with hypothesis testing or problem solving approaches, both of which become increasingly important for older students. For students in late elementary and secondary schools, careful review of students’ histories is very important. Use Validated Interventions General education is the first intervention. Many authors (Kame’enui and Simmons, 2002) conceptualize the first phase of “intervention” to be at the general education basic or core curriculum level. From this perspective, use of a research based core curriculum is a necessary precondition for adopting RTI. Such curricula provide development in the instructional components identified as essential by the National Reading Panel: phonemic awareness, systematic phonics, fluency, vocabulary, and text comprehension. A number of published curricula have been aligned with these instructional components. An issue for consideration in an RTI model is that there should be a mechanism in place for judging the fidelity of implementation of any identified curriculum. Interventions are supported by research. With respect to more intensive individual interventions, the body of literature on validated procedures is growing. Gresham (2002) reviewed the current body of literature and reached the following conclusions: 1. The concept of a validated intervention protocol is supported by research. 2. A combination of “Direct Instruction” and “Strategy Instruction” is the most productive in effecting growth. The use of validated instructional protocols presumes that the school has identified sets of instructional interventions, usually of increasing intensity, that have been demonstrated to be effective. These interventions are varied by curriculum focus, group size, frequency, duration, and motivational conditions. Often, these variables are modified in relation to student characteristics. Using Direct Instruction and Strategy Instruction means the school has adopted interventions that are based on these well established instructional approaches. Direct instruction models are characterized by relatively more teacher directed instruction and less independent seatwork. Information is carefully structured and sequenced and is actively presented so as to maximize student attention, involvement, and practice. Consistent procedures for cueing, prompting, and correction are utilized within the context of on-going assessment of student understanding (Huitt, 1996). In direct instruction models, student mastery is carefully defined and achieved before moving to the next step in the instructional sequence. OrPTI Guidance, September 2005 7 Strategy instruction employs specific, highly elaborated instruction in text comprehension. Validated models of strategy instruction use instructional techniques that are consistent with direct instruction. Modeling and planned generalization of skills are typical instructional steps in strategy instruction. Several authors (Pressley, 2000) have described instructional sequences appropriate to strategy instruction. Distinguish Between Types of Learning and Performance Problems Gresham (2002) describes relevant research demonstrating it is possible to determine if a student’s problems are performance problems (can do, but doesn’t) and instructional problems (wasn’t taught or wasn’t available for teaching). In the case of performance problems, an intervention might alter the motivational conditions (contingencies associated with) of a task. Howell and Nolet (2000) detail a number of ways to alter instructional conditions to assess the effects of motivation and other variables on acquisition of knowledge. In the case of instructional problems, the larger instructional context might be analyzed more thoroughly—for example, assessing the growth trends of all children in a class or grade level—to determine if there is a curriculum and instruction problem contributing to skill acquisition for the group as a whole. These distinctions are often made within the context of what is termed a “problem solving” approach. In this approach, hypotheses are developed that “compete” with the explanation that a child has a disability. These hypotheses are tested by first providing interventions that address the problem identified and then evaluating the student’s progress. For example, changing schools frequently is often a contributor to students’ struggles. In a problem solving approach, the student might be provided with a moderately intense reading program at an appropriate curricular level. By tracking the student’s progress carefully, the team might conclude that the student’s strong response is an indicator that interrupted instruction, rather than the existence of a learning disability, is a reasonable explanation for the student’s academic struggles. Determine the Effects of Instruction and Make Decisions about Cutoff Criteria When beginning to use RTI, the first question practitioners often ask is: “How much progress is enough?” The second question, closely following, is “When is an intervention special education?” Success in answering the first question is predicated on the ability to sensitively measure growth and to know what benchmark the student is working toward. Research in applied behavior analysis and curriculum based measurement inform the practices necessary to track the effects of interventions. A regular, reliable progress monitoring tool, such as an oral reading fluency measure, must be adopted. The school must also know what is expected of the typically progressing student. Data must be plotted and reviewed, and decisions must be OrPTI Guidance, September 2005 8 made when the data are examined. Most systems develop decision making rules to guide this process. For example, a decision making rule might be “Change the intervention after one week of data points that do not meet the student’s aim line.” The second question, “When is an intervention special education?” is one that involves a system level decision as well as a clinical decision. First, a socially determined cut off for “functional” performance must be established. This is usually defined as being in the “average” range on a normal distribution. Secondly, an informed group of professionals needs to evaluate the intensity of the intervention provided and either test or make a professional judgment about the effect of removing an intensive intervention. Response to Intervention Models A number of models have been utilized to implement RTI. Various authors have labeled their approaches as being of a specific type—such as those described below—but in reality the approaches share similarities. For example, the “problem solving” model is used at certain points in the “tiered model.” Both the problem solving and the tiered models may involve direct teacher referral to teams that may result in a form of what has been thought of as pre referral intervention. Problem Solving or Hypothesis Testing Problem solving approaches typically involve a team of teachers who engage in a systematic process of problem identification and intervention implementation. The underlying assumption in problem solving is that the presence of a disability is the least likely and therefore least common explanation for failure. In problem solving approaches, teams of teachers and other specialists will typically review a student’s history and known attributes in an attempt to identify issues other than disability that would explain the student’s failure. Problems a teacher or team investigates could include interrupted school experiences caused by frequent moving or illness, lack of student “availability” for instruction due to trauma or behavioral challenges, inadequate previous instruction, or the presence of other disabilities. Marston (2002) describes the widespread use of the problem solving approach in the Minneapolis Public School system. This system uses problem solving within the context of “Intervention Assistance Teams.” In Minneapolis, general education teachers are trained to identify problems, design interventions, and determine whether their interventions are effective. If they are not, the Intervention Assessment Team assists in developing and providing other interventions. If those interventions fail, the student is referred to a “Student Support Team” for a special education evaluation. This system relies heavily on OrPTI Guidance, September 2005 9 the capacity of its general and special education teachers to use curriculum based measures (CBM) to track student progress and has well defined procedures for moving students through levels of intervention. In order for a problem solving approach to meet the general IDEA 2004 evaluation requirements, meet RTI requirements, and overcome shortcomings associated with more traditional assessment models, schools must adopt the following system components: 1. Use of decision rules to prompt referral 2. Adopted standards for intervention design 3. Uniform progress monitoring procedures 4. Decision rules for judging effectiveness of interventions The relative strengths and challenges inherent in a “pure” problem solving approach are summarized below: Strengths Problem solving approaches address the “exclusionary” requirements of LD evaluation. A problem solving approach fits easily into systems that many schools already have in place, such as teacher assistance teams. Problem solving approaches may not require the adoption of extensive new assessment technology. Educationally relevant information may be gathered throughout the process. Challenges Identified problems are often ones that cannot be directly addressed by schools. Academic problems induced by external factors such as lack of preschool experience or behavior difficulties may coexist with learning disabilities. Problem solving models alone do not address problems like referral bias. Pre Referral Approaches Pre referral models were conceived in the 1980’s as a method of addressing over-identification in special education through prevention of inappropriate referrals. Essentially, this model systematizes requirements that general education teachers modify instructional and classroom management approaches in order to better meet the needs of diverse learners. The assumption is that OrPTI Guidance, September 2005 10 poor academic performance is often the reflection of students’ unmet instructional or curricular needs rather than an intrinsic disability. Through pre referral, teachers are guided to differentiate instruction in order to maximize the number of students who benefit from the general education program. The most typical pre referral models have at their heart a teacher assistance team, known by a variety of names including care teams, student study teams, and student assistance teams. The team processes cases of students who are identified by their teachers as struggling. The team may design specific interventions or make suggestions to the teacher for possible interventions. If positive results are documented, no referral is made to special education. If, however, a lack of improvement is noted, the student is referred for a special education evaluation. Major shortcomings of the pre referral model for use in RTI include referral bias and negative perceptions of the process among classroom teachers. Factors such as teachers’ years of training and experience and the socioeconomic status of students have been shown to influence which students are identified as struggling (Drame, 2002). Referrals may be based as much on how overwhelmed teachers are feeling at any given moment as on a student’s level of skill development or performance. Additionally, the pre referral process can be viewed as a series of hoops through which a teacher must jump before being “allowed” to make a special education referral rather than as a meaningful avenue for addressing students’ needs (Slonski-Fowler & Truscott, 2004). Perhaps the most significant drawback of a pre referral model is that the teacher must deal with each struggling student individually. Given that up to 20% of students are likely to have significant difficulty learning to read (Shaywitz, 2004), this approach makes it difficult to provide meaningful resources to all students. While it is likely that students with the most apparent and immediate needs will be referred for interventions, intervening with students one by one forces teachers into educational triage. Meanwhile, students with marginal problems will continue to struggle and perhaps fall further behind (Gerber & Semmel, 1984; Gresham, MacMillan & Bocian, 1997). Pre referral models may be more or less prescriptive with respect to decision rules for identifying students, intervention design, and progress monitoring. Many of the model’s weaknesses can be addressed by adopting standard practices that are designed and monitored by the teacher assistance team. Adopting procedures to ensure uniformity in decision making is critical to utilization of a pre referral model for RTI. Without specific system components, a pre referral system will not meet the general IDEA 2004 evaluation requirements or the RTI requirements, and will fail to remedy the shortcomings of traditional assessment paradigms. Specifically, the following would be required: 1. Use of decision rules to prompt referral 2. Adopted standards for intervention design OrPTI Guidance, September 2005 11 3. Uniform progress monitoring procedures 4. Decision rules for judging the effectiveness of interventions Pre referral strengths and challenges include: Strengths Many school districts currently have pre referral systems in place. Pre referral utilizes a team approach to identifying students. Pre referral provides for systematic response to students’ difficulties before evaluation. Pre referral has the potential to build capacity for individual teachers to differentiate instruction for struggling learners. It may be combined with typical components of other models, such as problem solving approaches. Educationally relevant information is gathered throughout the process. Challenges Pre referral does not inherently address the problem of referral bias, as it depends on idiosyncratic responses of teachers to academic difficulty. Traditionally, pre referral models do not use a prescribed intervention protocol. The reporting of effects of intervention is often anecdotal and lacks standard format for data presentation. Students are dealt with “one at a time,” which may delay intervention to students with less severe deficits. Tiered Intervention The three-tiered model is based on literature in the area of public health (Caplan & Grunebaum, 1967) and Positive Behavior Support (Walker et al., 1996). Using the public health analogy, systematic practices for healthy individuals (strong and normally developing readers) and those at risk of developing health conditions (students showing early signs of struggling) will prevent severe problems from developing and will also allow for identification of individuals with the potential to develop severe problems. The underlying assumption of this prevention oriented approach is that approximately 80% of students will benefit from implementation of a researchbased core curriculum program that is being delivered with a high degree of fidelity. This level of “intervention” is referred to as “primary” or “Tier I.” An estimated 15% of students will need additional intervention support beyond the OrPTI Guidance, September 2005 12 core curriculum (“secondary” or “Tier II”) , and about 5% who have not responded to primary and secondary efforts may require more intensive individualized support ( “Tertiary” or “Tier III” level). This approach requires the use of a universal screening program. The threetiered model has been implemented successfully in Oregon as the Effective Behavior and Instructional Support system (Sadler, 2002). In this model, teams of teachers examine a standard set of data that is gathered on a periodic schedule. Students are sorted into groups that are provided with increasingly intensive interventions depending on their achievement and response to intervention. Movement through the tiers is a dynamic process, with students entering and exiting according to their progress data. In this model, it is assumed that students who do not respond to the most intensive intervention are likely to have a learning disability. Frequently, the tiered approach is combined with more traditional assessment models or with problem solving procedures before a student is determined to have a disability. This approach requires “blurring” of the lines between general and special education, as well as close cooperation or merging of compensatory education services and services for English language learners. Relative strengths and challenges of the tiered model include: Strengths All struggling students are identified. Prevention and early identification are possible. Students may be “sorted” into levels of severity and interventions may be tailored to each group. Decision making is based on standardized progress monitoring information. Intervention decisions can be standardized. It may be combined with typical components of other models, such as problem solving approaches. Educationally relevant information is gathered throughout the process. Challenges Resources must be committed for universal screening. It requires skill grouping across classes to provide interventions of sufficient intensity. Ensuring that every child at risk is identified and provided intervention requires establishment of broad groupings, which may result in allocation of resources on children who are not actually in need. OrPTI Guidance, September 2005 13 The most suitable screening and progress monitoring tools are available in reading. Tools in other areas are not as well established. IDEA 2004 Evaluation Requirements and Traditional Assessment Practices Regulatory Requirements IDEA 2004 requires careful attention to how special education evaluations are conducted. The statute places emphasis on linking student assessment to student instruction through the use of RTI. It is important to remember that RTI is allowed as a component of evaluations for LD, but only one component. Districts must be aware of and ensure that their procedures address the following requirements: A “full and individual initial evaluation” shall be conducted. . . “to determine whether the child is a child with a disability. . . and to determine the educational needs of the child (20 U.S.C. 1414 (a)(1)(A) and (C) (i) (I) and (II).) These requirements and those discussed below obligate teams to consider all aspects of a child’s functioning. While RTI may address whether a child responds to intervention, it may not adequately describe the effects of emotional and behavioral problems or language and cultural factors on performance. It is important that, at a well articulated point in any process, formal and individual evaluation is conducted and that areas in addition to those addressed in the RTI process are considered. An initial evaluation must be conducted within “60 school days” of obtaining parental consent (OAR 581-015-0072). . . and “The agency proposing to conduct an initial evaluation. . . shall obtain informed consent from the parent of such child before conducting the evaluation.” (20 U.S.C. 1414 (a)(1)(D). These requirements mean that the process for RTI must be carefully tracked. It must be clear to teams that there is a specific point at which the intervention process is part of a special education evaluation. Parental consent must be obtained at that point, and the parent must understand that the procedure being implemented will contribute to a decision about whether the student has a learning disability and is eligible for special education. Evaluation procedures must: …“use a variety of assessment tools and strategies to gather relevant functional, developmental, and academic information, including information from the parent” and may “not use any single measure or assessment as the sole criterion.” The procedures must include the use of “technically sound instruments that assess the relative contribution of cognitive and behavioral factors.” (20 U.S.C. 1414 (b)(2)(A)(B) and (C). Further, (3)(A)(i-v) continue the requirements that nonbiased assessment procedures are used and that procedures are administered by qualified, trained, and knowledgeable personnel. (3)(B) reiterates that the child must be “assessed in all areas of suspected disability.” These requirements make it clear that a single form of OrPTI Guidance, September 2005 14 assessment—RTI—may not be used to either find children eligible or define all of their educational needs. Teams must continue to consider whether a student is most appropriately identified as a child with LD as opposed to another disability, such as emotional disturbance. They must also design individual evaluations that are tailored to children’s presenting issues. (3)(A)(i) and (ii) and (5)(C) require that assessments conducted “are selected and administered so as not to be discriminatory on a racial or cultural basis” and are “provided and administered in the language and form most likely to yield accurate information on what the child knows and can do academically, developmentally and functionally”. . .and that a child may not determine a child is eligible for special education if the “determinant factor for such determination is. . .limited English proficiency.” The effects of second language acquisition and cultural variations must be considered for English language learners and interventions that are designed for those students must be appropriate. The procedures used in RTI are aligned with recommended best practices for ELL students (need a reference here), but it is important that the design of interventions and interpretation of ELL students’ responses to interventions be informed by individuals who are very knowledgeable about the education of ELL students. The Role of Intelligence Testing in RTI The general IDEA 2004 evaluation requirements dictate that teams make individual decisions about the scope of evaluation and specific evaluation tools that are used for a student. However, the question of whether or not to give an IQ test to a student is of great interest to professionals as they contemplate this change. The final section of this paper reviews many of the problems related to using intelligence testing with students who have or are suspected of having learning disabilities, and readers are encouraged to review that information when making policy decisions about the use of IQ tests. Generally, teams are encouraged to use IQ tests with discretion. Certainly they must be used if the team suspects mental retardation. There is substantial overlap between skills measured on IQ tests and academic skills, and poor achievement affects students’ performance on components of IQ tests. In short, there is limited value in profiling a student’s cognitive skills in order to inform instruction. (Stanovich, 2005). Summary RTI models have the capacity to improve outcomes for and provide support to students who are both low achieving and LD. They do, however, require substantial cooperation between regular and special education. They also require that procedures be used within general education to impact the general education curriculum and teacher practices. Widespread progress monitoring of OrPTI Guidance, September 2005 15 all students, systematic intervening within general education, and collegial problem solving are hallmarks of RTI. IDEA 2004 anticipates the resource requirements of such an approach, allowing for use of up to 15% of Part B funds for “early intervening” services for students who are not yet identified as having a disability. Districts can both adopt a new diagnostic approach and benefit children before their low performance becomes an intractable achievement deficit that may be accompanied by low motivation and behavioral problems. However, districts must carefully determine which model of RTI is most appropriate within their system and implement standardized procedures aligned to state criteria. OrPTI Guidance, September 2005 16 Section Two Implementing Response to Intervention (RTI) Response to intervention assessment requires changes in the ways resources are used and a very close relationship between general and special education. General educators need to understand the approach and why all of their students need to be closely monitored—especially in the development of early academic skills. Special educators must understand the limitations of traditional assessment systems and adopt highly prescribed and systematic interventions. Most importantly, general and special educators need to work together to implement and maintain the system. This chapter details the following system requirements for RTI: 1. Leadership 2. Teaming 3. Use of a research based core reading curriculum 4. Valid screening or identification procedures and decision rules 5. Adopted intervention protocols and progress monitoring 6. Policy and procedure development including special education procedures 7. Capacity building Leadership Moving from a discrepancy approach to RTI requires on-going support to teams and to individuals. A leadership team at the district level will help schools move forward and sustain new practices. This team needs to be able to: Provide expertise when problems are encountered or practices are questioned. Provide training related to LD identification including traditional practices and the rationale for RTI. Identify the need for and provide support to teams with respect to research based interventions and progress monitoring methods. Help obtain and commit resources for screening, assessment and interventions. Interpret new information in the field regarding LD. Judge the fidelity of implementation of components of RTI and trouble shoot. Plan to sustain the system. OrPTI Guidance, September 2005 17 Horner and Sugai (2000) have worked extensively with school wide systems that address behavior supports through team processes, and they emphasize the importance of the school principal having a primary role on any such team. The philosophical and instructional leadership provided by the principal is essential to a team’s ability to establish its mission, overcome difficulties and sustain its work over time. Teaming Teaming is an essential component of an RTI system. As described throughout this paper, RTI requires cooperation among special education, general education, and compensatory programs such as Title I or Title III (English language learners/ELL). Considerations to take into account include team membership, team structures, and teamwork. Team Membership Experience in implementing Effective Behavior and Instructional Supports (Sadler, personal communication) dictates that decisions about team membership be considered carefully. Generally, the team must have one or more members who: Have the authority to allocate school resources and assign work (administrative support) Can provide leadership for the team, organize and implement agendas, monitor role clarity and fidelity Are able to effect changes in the general education instructional program for groups of students (such as skill grouping) Can organize and present screening data Are able to plan for and provide research based individualized interventions (such as a small group working on decoding multi-syllabic words) Can set goals for students, plan for progress monitoring, plot data, and interpret data to determine the effectiveness of interventions Are able to train classroom teachers and paraprofessionals to progress monitor and provide interventions Represent the involvement of special education, ELL, Title, and other support programs Team Structures Schools may find that more than one team best serves their needs. For example, initial data analysis and planning may be accomplished through a grade level team. At that level, a group of teachers might find that fewer than OrPTI Guidance, September 2005 18 80% of their students are meeting expectations and decide to investigate ways to strengthen their instructional program. If the core program is meeting the needs of at least 80% of the students, the teachers may decide to strengthen instruction for students who are marginally below expectations through skill grouping and differentiating instruction across classes. This level of team must have measurement, progress monitoring, and administrative resources available. Another level of the team might meet to plan interventions for students who are not making expected progress in the programs designed by the grade level teams. This team must maintain strong ties to the general education classroom and all of the capacities listed above. Figure 1: Two General Education Teams Manage RTI Prior to Referral On-going data gathering and analysis at group and individual level. Decision rules drive decisions about including students in interventions and referral decisions. Standard formats are used for data presentation and analysis. Grade Level Team evaluates effectiveness of core program and plans initial group interventions. Centralized team plans targeted small group and individual interventions. Evaluation Team plans and conducts RTI related specifically to eligibility. Teams move students through interventions that increase in intensity based on individual student outcomes. Some schools use one central team to perform all functions of data analysis and intervention planning, at the classroom, small group, and individual level. Using a single level team requires a substantial commitment of time and resources to both conducting the work of the team and maintaining the “health” of team functioning. Teamwork Teaming in order to analyze student progress using standardized data and decision making means that on occasion individuals will need to engage in OrPTI Guidance, September 2005 19 difficult communication about student outcomes, fidelity of implementation of curriculum, or special education decisions. Successful teams establish working agreements about conducting meetings, decision making, interactions, and roles. Examples of such agreements are: Team members will encourage each other to express their opinions. Decision rules will be used to guide the team’s work. Once a decision is made, team members will support that decision. Meetings will start and end on time. Team members will bring necessary information to the meetings. The agenda will be followed. Decisions will be made through a consensus process. The principal makes final decisions about allocation of resources. Teams should revisit their working agreements periodically to ensure they continue to be relevant and are being implemented. Planning is Essential As the team is formed, a year long plan of work should be established. There will be a cycle of reviewing school wide data, group intervention data, and individual intervention data that requires projecting agendas for meetings and planning to organize information to be considered. A typical calendar used by the Oregon EBIS (Sadler, 2002) model follows: Figure 2: Example of a Yearly RTI Team Plan of Work Beginning of year Define group membership, establish group norms, plot work for the year. Review current school wide data on academic achievement, behavior, attendance, etc. Quarterly Gather and review data (based on screening or in class assessments). Review membership in groups considered at benchmark or at risk. Weekly Review data on students who are in intensive interventions. Change membership of intervention groups or change individual interventions. End of year Review data on all students based on final quarterly and statewide assessment. Identify students for extended year opportunities. Identify students for immediate intervention or evaluations to be implemented in September. OrPTI Guidance, September 2005 20 Use of a Research-Based Core Curriculum IDEA 2004 requires teams to determine students not eligible for special education if their difficulties are attributed to lack of instruction in the essential components of reading instruction as identified in No Child Left Behind (phonemic awareness, alphabetic principle, fluency, vocabulary, and comprehension). Also, when implementing RTI teams must have confidence that the general core curriculum provides students with an appropriate opportunity to learn. Effective core curricula are expected to provide sufficient instruction so that at least 80% of students meet expectations without additional support. Information on research-based core curricula may be found at Oregon’s Reading First Project website: http://oregonreadingfirst.uoregon.edu./instruction. Reading is set apart as especially important because the majority of students with learning disabilities are identified with problems learning to read. Other academic areas are substantiated with less research, but curricula and instruction may be validated by meeting these guidelines: 1. The curriculum that is being used has been analyzed and is aligned with benchmarks. 2. Instruction is intense, regular, and differentiated to meet the skill needs of individual students. 3. At least 80% of students are meeting expectations such as benchmarks. It is particularly important to examine the “80%” criterion. This expectation is a general guideline, and teams should adjust that expectation to a higher level if the general achievement in the school is typically higher than 80%. In some schools, the expectation is more appropriately 85% or even 90%. Performance in each classroom is expected to be close to the school average. While the criteria may be adjusted upward, it should not be adjusted downward. It should be assumed that, if 80% of students in a district, school, or classroom are not meeting benchmarks, the problem is with either the content of the core curriculum, or intensity and frequency of instruction. OrPTI Guidance, September 2005 21 Figure 3 is a conceptual representation of the 80% rule applied, with increasingly intense interventions. Figure 3: Conceptual Depiction of the 80% Rule All students are provided with research based instruction. If 80% are not meeting benchmark, core practices are evaluated. About 15% of students are provided with research based interventions of moderate intensity. About 5% of students are provided with research based intensive interventions. Valid Screening or Identification Procedures and Decision Rules School personnel need to know when a student is at risk of failure in a core academic subject. Whether a district adopts a problem solving, pre referral, or tiered model of RTI, teachers or teams need to know when to select a student for intervention. This requires that valid data are examined on a regular schedule and that students are selected for intervention on this basis. Data that may inform these decisions include: 1. Dynamic Indicators of Basic Early Literacy Skills 2. Curriculum Based Measures 3. Fluency measures with norms that are local or based on national studies 4. Statewide assessments 5. Locally developed measures that can be interpreted on consistent, objective criteria 6. Behavior and attendance data that can be interpreted on consistent, objective criteria 7. Teacher concern Using clearly defined criteria and decision rules—for example, “Students who are in the lowest 10% of the class will be selected for interventions”—helps to OrPTI Guidance, September 2005 22 overcome problems in referral bias, lack of teacher experience, or differences in teachers’ level of tolerance with respect to students who are struggling. These decision rules are those that are used to select students for intervention. Decision rules are also necessary to ensure that students who are not responding adequately move to more intensive or appropriate interventions, and that a decision is made to complete the special education referral process when needed. An example of this kind of decision rule is “Change the intervention when the student does not meet the aim line for three consecutive data points.” These types of rules are those that govern the intervention process. It is very important that data are reviewed on ALL students in the school, on an ongoing basis. Even though students may be placed in special education, ELL, or Title I, their achievement and progress is part of the total system and must be continuously tracked. Adopted Intervention Protocols and Progress Monitoring Intervention Protocols There is some concern that RTI based decisions will lack uniformity. This concern is based at least partially on the difficulty in documenting what interventions have been provided and their levels of intensity and duration. Those concerns may be addressed by carefully standardizing interventions. Gresham (2002) reviewed research in reading interventions and determined that a combination of Direct Instruction and Strategy Instruction produces the greatest effects for struggling students. Other authorities (National Reading Panel, 2000; Shaywitz, 2004) add Fluency Instruction as an important component of interventions for many students. Examples of curricula that may be used for interventions may be found at http://oregonreadingfirst.uoregon.edu./instruction. Interventions become increasingly intense as students do not respond adequately. Intensity is achieved by changing group size, expertise of the teacher, duration or frequency of lessons, or motivation. As interventions become more intense, it is difficult to provide both general education curriculum and interventions to a student. It is recommended that when there simply isn’t enough time in the school day to provide an intensive intervention, programming like extended school day be considered. Another approach is to provide the systematic basic skills instruction and practice in the intervention setting and include students in language and comprehension instruction in the general education classroom. For example, in math the student would be included in the general education classroom for conceptual, vocabulary, and math reasoning instruction. A menu of interventions should be OrPTI Guidance, September 2005 23 developed that match area of deficit, curricula, and intensity to specific student profiles. The following steps may be used in designing an intervention: 1. Identify students with similar skill deficits (e.g., math fact fluency). 2. Specify each child’s deficit level (e.g., writes 10 correct facts per minute). 3. Identify a curriculum that is specific to the skill deficit(s). 4. Identify an instructor who has been trained to use the curriculum. 5. Decide how long the intervention will progress before review. 6. Develop a progress monitoring chart for each student that includes a clearly marked benchmark and aim line. Progress Monitoring Progress monitoring is assessment of students’ academic performance on a regular basis in order to determine whether children are benefiting from instruction and to build more effective programs for those who are not. Standard methods of progress monitoring prevent inconsistency in decision making and eligibility decisions. Progress monitoring for these purposes must include clear benchmarks for performance and reliable, easy to administer measures such as curriculum based measures (CBMs). Progress monitoring involves the following steps: 1. Establish a benchmark for performance and plot it on a chart (e.g., “read orally at grade level 40 words per minute by June”). It must be plotted at the projected end of the instructional period, such as the end of the school year. 2. Establish the student’s current level of performance (e.g., “20 words per minute”). 3. Draw an aim line from the student’s current level to the performance benchmark. This is a picture of the slope of progress required to meet the benchmark. 4. Monitor the student’s progress at equal intervals (e.g., every third instructional day). Plot the data. 5. Analyze the data on a regular basis, applying decision rules (e.g., “the intervention will be changed after 3 data points that are below the aim line”). 6. Draw a trend line to validate that the student’s progress is adequate to meet the goal over time. OrPTI Guidance, September 2005 24 Figure 4: An Example Progress Monitoring Chart with Aim Line WIF: Correctly Read Words Per Minute 100 90 The X is the end-of-term performance goal. A goal-line is drawn from the median of the first three scores to the performance goal. 80 70 X 60 50 40 30 20 10 0 1 2 3 4 5 6 7 8 9 10 Weeks of Instruction 11 12 13 14 Source: National Center on Student Progress Monitoring website: www.studentprogress.org/library/training.asp Determining Trends It is very important that data be analyzed sufficiently to determine whether changes in instruction are required for the student to meet the performance benchmark. This analysis is enhanced when data are graphed. Trend lines, graphic indications of a student’s overall slope of progress, are necessary to determine whether progress is sufficient to meet the goal. There are several technical approaches to determining trend lines, among which is the Tukey Method (illustrated in Figure 5). Robust progress monitoring procedures such as graphing results and using trend lines are required in order to apply consistent decision rules. Examples of decision rules are found in the “Policy and Procedures” section of this chapter. An excellent resource for learning about progress monitoring and establishing goals may be found at the website for the National Center on Student Progress Monitoring, found at www.studentprogress.org. OrPTI Guidance, September 2005 25 Figure 5: Developing a Trend Line Using the Tukey Method Step 1: Divide the data points into three equal sections by drawing two vertical lines. (If the points divide unevenly, group them approximately.) WIF: Correctly Read Words Per Minute 100 90 Step 2: In the first and third sections, find the median data-point and median instructional week. Locate the place on the graph where the two values intersect and mark with an “X.” 80 70 60 50 Step 3: Draw a line through the two “X’s,” extending to the margins of the graph. This represents the trend-line or line of improvement. X 40 X 30 (Hutton, Dubes, & Muir, 1992) 20 10 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Weeks of Instruction Source: National Center on Student Progress Monitoring website: www.studentprogress.org/library/training.asp Policy and Procedure Development including Special Education Procedures Adopting RTI This paper has emphasized that RTI is a system that affects both general and special education. Districts that have successfully implemented these approaches experience substantial system-wide benefits for all children. However, obtaining “buy-in” and cooperation for use of resources is essential. Administrative support from the top down and teacher support from the bottom up are vital to success and sustainability. Initially, RTI will require extra resources for training and time for teams to work together. Support services such as ELL and Title I may need to be reorganized. Funds may need to be set aside to provide interventions. Commitment and planning need to be in place before RTI is implemented. IDEA 2004 offers districts the opportunity to support the RTI process by using IDEA funds for “early intervening services.” These are coordinated services that are preventative in nature and function within the general education context. OrPTI Guidance, September 2005 26 Defining and Adopting Procedures When moving to an RTI approach, a set of fluid activities (data review, intervention implementation, and analysis) are used much like we have used traditional testing instruments. These activities may be difficult for some teams to track. Individuals must conduct those activities in standardized ways, documenting their work, and using standardized decision making guidelines. This prevents arbitrary decision making, and ensures students move through the system and are considered for evaluation and eligibility in a timely manner. Decision Rules This essential procedural component has been referenced several times. An example of decision rules used by the Effective Behavior and Instructional Support (EBIS) (Sadler, 2002) are: 1. Organize the lowest 20% of students in the group (class, grade level, or school) to receive interventions. 2. Students in group interventions are monitored weekly. 3. Students in individual interventions are monitored at least 1 time weekly. 4. Change interventions when 3 consecutive data points do not meet the student’s goal line. 5. Move students to an individual intervention after two unsuccessful group interventions. 6. Refer a student for special education after one unsuccessful individual intervention. Parental Notice and Consent Procedures must establish clearly when and how parents are involved in the RTI process. Questions to answer ahead of time include: “When are parents invited to team meetings?” “When are parents provided with procedural safeguards?” “When is parental consent required?” In the EBIS system, parents are notified of any individual intervention. Since it has been found that a second individual intervention typically is provided to students who are or will be referred for special education, it is at this point a special education referral is made and consent for evaluation is obtained. Special Education Procedures As described in the general section on RTI, all of the evaluation requirements for special education remain in effect when implementing this approach. This means that teams need to be very clear about an evaluation planning process that regards the use of response to intervention as one component of a full and OrPTI Guidance, September 2005 27 individual evaluation. Districts need to develop well defined procedures and ensure teams are trained before implementing RTI. Figure 6: Example of a Student’s Movement through RTI with Procedures Noted Parents notified by classroom teacher Formal notice; parents are invited to participate in process Parents notified by classroom teacher Evaluation planning meeting with parents; procedural safeguards and parent consent. 60 day timeline starts Evaluation planning meeting, procedural safeguards provided, consent obtained, 60 day timeline starts. Evaluation Planning and Eligibility Determination Using a response to intervention model (RTI) to decide a student has LD involves systematic application of professional judgment. Through the review of data obtained from multiple sources, consideration of those data within specific contexts, and thoughtful discourse, a team is prepared to make an eligibility decision. More complex than relying on a simple numerical formula, this process produces decisions that reflect the benefit of collective knowledge, expertise, and insight of the team. OrPTI Guidance, September 2005 28 Teams should think of the eligibility determination in terms of a conversation through which issues are viewed from several perspectives, competing factors are weighed and sorted, and the most likely explanation for a child’s lack of achievement is found. Remember, the key issue teams are investigating is whether students evidence a dual discrepancy, that is, low achievement as well as poor progress when provided with intervention. Use the following five questions to guide the conversation, and ultimately, the decision and report of findings: 1. Is our information complete? Teams must keep in mind that RTI is just one component of a comprehensive evaluation under IDEA 2004. In addition to the specific information regarding the student’s response to intervention, the team also must gather the following information: File review: Thorough review of a student’s file provides critical information within the RTI model, especially as students move through the grades. Frequent moves between schools and excessive absences should be noted, as should participation in special programs such as Title I or ELL. Comments on reports cards can provide a surprisingly helpful picture for the team, especially in creating a historical record of the child’s achievement in the current area of concern. Note: While the file review is required for the eligibility determination, it is most helpful to complete it prior to the special education referral. Information gleaned from a student’s file is instrumental in identifying needs and developing interventions to address those needs. It is strongly recommended that teams plot the student’s achievement, absenteeism, and other important factors so that there is a chronological history by school year. By doing so, teams may be able to see relationships between achievement and events in the student’s life. This information addresses the exclusionary factors (see below) and helps the team consider other explanations for the student’s difficulties. Consider the following example: o Tasha is an ELL student who moved to the United States when she was four years old. Now in fifth grade, her low achievement is a concern to her teacher. She is noted to have good English social language skills. When the team conducts a file review, they find that Tasha’s family moved from town to town until she was in second grade. She spent second, third and fourth grade at the same school. The team examines her academic growth on statewide assessments and notes that, from second to third OrPTI Guidance, September 2005 29 and third to fourth grades, Tasha’s RIT scores increased almost 1.5 times expected growth, with minimal ELL services.Tasha’s file review suggests she is progressing in a way not typical of children with LD. Observation: Consider the child’s behavior, and characteristics of the environment, while working in the area of difficulty within the regular classroom. Assessments in other areas of concern: The team must address all areas of concern raised by parents and staff in the initial referral and during the evaluation planning process. While this doesn’t mean that formal assessments will be completed in response to every issue raised, it is necessary to document consideration of each. If other disability categories are considered by the team, all of the required elements for those categories must be completed. Assessments to determine the impact of the disability and educational need: Progress monitoring data gathered through the intervention process is the primary assessment in this area, with published achievement tests serving to complete the picture. Though not required elements of evaluation, teams may determine that the following information is needed on a case-by-case basis: Developmental history Assessment of intellectual ability Medical statement 2. Does the student have very low skills? Teams consider data from multiple sources, including CBMs, DIBELS, Statewide Assessments, published achievement tests, and work samples. Viewing the student’s skill development within the context of age level expectations is key – are these skills very low in comparison to other students this age? Reporting results in standard scores, percentiles, and POP scores (statewide assessments) provides this important context. 3. Does the student fail to learn at a sufficient rate in response to intensive, research-based instruction? Careful consideration of the child’s progress over time, relative to expected progress, is required. The team reviews the intensity and duration of instruction in relationship to the skills gained. It is helpful to find a way to assign “weight” to both the intervention and the progress, perhaps visualizing each as rocks on a scale. Consider these examples: OrPTI Guidance, September 2005 30 Example A: A fourth grade student receives 10 minutes per day of fluency instruction that is in addition to the core reading program. Oral Reading Fluency grows from 90 to 103 words per minute during a three week period. The grade level target is 120 words per minute, and the student’s progress is clearly following the aim line to hit the target. This intervention, relatively “light”, could be pictured as a small rock on one side of a scale. The progress, fairly “heavy”, could be pictured as a medium rock on the other side of the scale. In this case, the student is responding well to the instruction, with progress deemed to “outweigh” the intervention. Example B: A first grade student receives 45 minutes per day of decoding and fluency instruction that is in addition to the core reading program. Oral Reading Fluency grows from 6 to 10 words per minute in an 8 week period, while other children in the intervention group have gained an average of 22 words per minute during this same time. It is clear that this child is not on track to hit the expected level of performance by the end of first grade. In this case, the intervention is judged to be quite “heavy” and can be visualized as a large rock on the scale. The child’s progress, in contrast, is “light”, best visualized as a small pebble on the opposite side of the scale. This child is resistant to instruction, failing to learn at a sufficient rate. Keep in mind that the answers to questions 2 and 3 must both be “yes” in order to determine that a student has a learning disability. Students with learning disabilities are those who, despite intervention too intense to be considered general education, demonstrate very low skills. The percentile used as a guideline for “how low” may vary depending on local norms, but will likely fall between the 20th and 30th percentiles. While this may seem relatively high performance given more traditional approaches that require a student to be at least below the 16th percentile, remember that our purpose is to catch students before they fall far behind, and to maintain their skills in a functional range. This is why the concept of a “weighty” intervention contrasted with a “light” response is so important. Additionally, in cases of students receiving intensive intervention and achievement above this “very low” range, teams may document that without continued intervention the student’s achievement will fall below the targeted percentile. 4. Do we have conflicting data and, if so, how do we make sense of it? Sometimes, teams will have some data sources that reflect very low skills and others that indicate better achievement. In these cases, the team must decide which sources are most valid and then justify the decision. This process involves consideration of the demands of each assessment, including content, speed, and fluency. For example, a child may score better on an untimed test of decoding skills in which self-corrections are counted as correct (such as many published achievement tests), than on a timed test of OrPTI Guidance, September 2005 31 decoding skills (such as Nonsense Word Fluency in DIBELS). In this case, a team may decide that the timed assessment is a more compelling indication of the child’s skill development because it reflects the level of automaticity of decoding, a key factor in reading development. In general, lower scores can be considered valid if they reflect performance on a test that is more comprehensive or involves more complex demands than the other assessment used. 5. Are there other explanations for the student’s low skills and lack of progress? IDEA 2004 carries forward “exclusionary factors” to be considered in eligibility determinations. That is, has the team considered competing explanations for the student’s lack of achievement? Best practice dictates that these issues be explored early in the intervention process. Specific factors to consider include: A lack of appropriate instruction in the area of concern: Are high levels of mobility and/or absenteeism the underlying cause of the student’s low skills? Has the student been enrolled in classrooms or schools in which research-based curricula weren’t used or quality of instruction is in doubt? Awkward as these issues may be for teams to discuss openly, they must be addressed and documented. The existence of a sensory problem or another disability: What are the results of current vision and hearing screenings, and is there a history of problems in either area? Are there suspicions of other disabilities and, if so, has the team documented consideration of each? In some cases, teams must carefully sort and analyze information in order to rule out behavioral or health issues or mental retardation as the source of difficulty. Limited English Proficiency: When a learning disability is suspected in a student for whom English is a second language, it is imperative that the team include an ELL staff member familiar with the child. In addition to the required components of a learning disabilities evaluation, the team should develop a language profile for this child that includes: o Current levels of oral, reading, and writing proficiency in both the primary language and English o The number of years the student has lived in the U.S. o The student’s educational history in the country of origin o Literacy development of other children in the family o The primary language in the home o The parents’ literacy profile OrPTI Guidance, September 2005 32 Deliberations of the team will center on this child’s academic achievement in comparison to other ELL students with similar language profiles. In the judgment of the team, does the student’s ELL status fully explain the low skills? Environmental or Economic Disadvantage: It is important for the team to thoroughly explore family stressors that may be impacting academic achievement. Factors to consider include frequent moves, homelessness, divorce, unemployment, and extended illnesses or death in the family. Additionally, document whether the child has had access to enriching experiences such as opportunity for conversation with adults, pre-school, and books in the home. The final determination of eligibility will come out of this guided conversation. Team members will recognize students who, despite intensive and systematic instruction, fail to gain basic skills at a satisfactory rate. Some find this process intimidating at first, as it requires conclusion based on professional judgment. Keep in mind, however, that these judgments are based on expertise coupled with hard data. Made with the benefit of a team approach, these are decisions that make sense in light of current research, educational need, and practice. Written Report IDEA 2004 requires that teams produce a written report to document the eligibility determination process under an RTI approach. Much more than merely reporting scores on tests, this report serves to document the thinking that lead to the eligibility decision. Districts are encouraged to adopt a standard template for LD Eligibility Reports and require its use in all cases. In training staff to adopt a uniform approach to LD Eligibility Reports, it is helpful to provide a checklist for staff to use in evaluating reports they produce. Key components of the report template and checklist should be the same. OrPTI Guidance, September 2005 33 Checklist for Learning Disabilities Eligibility Reports The following elements are required for each section of LD Eligibility Reports. If information is missing, or questions are unanswered, the team is not ready to make an eligibility determination. Section 1: Background Information Source(s) Name Cumulative file Age Individual Problem Solving Worksheet Birth date Report cards School Parent interview Grade Reason for the referral Brief description of the student’s language background, to birth. Statement detailing parent concerns and perspective, including background of disabilities, especially in areas related to current difficulties Summary of the student’s history and current status with special programs such as Title I and ELL Section 2: Students who qualify for special education as having Source(s) learning disabilities have very low skills. List state/district assessments (including DIBELS) Cumulative file o These are presented as #’s. Individual Problem o Test scores over time with comparison of actual Solving Worksheet growth to expected growth Report cards o RIT scores and corresponding percentiles State/District o State how the scores compare to the norm group Assessment Results (POP score) and benchmarks Individual List individual achievement test results in Standard Scores Achievement Test (SS) by subtest Results o Include SS for tests given in the past Work samples o For any subtests with SS below 90, describe the Teacher reports specific skill deficits that contribute to the low score Analyze the historical data. - Have scores always been low? o If not, a learning disability is unlikely. - Are scores relatively low? o Has the student had intensive assistance to maintain skills at that level? Are the state/district assessments and individual achievement tests consistent? o If not, get one more piece of information about the skills in question. o Confirm results with reports from teachers, which must be consistent. OrRTI Guidance, September 2005 34 If inconsistent results are reported, decide which is valid and justify the decision. o Consider the demands of each assessment (content, speed, fluency) o Lower scores may be considered valid if they reflect performance on a test that is more comprehensive or involves more complex demands than other assessments used. Finish with a summary statement about the student’s low skills. Section 3: The student has been provided the opportunity to learn the skills. Document the level of instructional stability throughout the student’s educational experience o Mobility (# of schools attended) o Attendance (over the years) o Reason(s) for excessive absences o Cumulative effect of absences (“Missed 20 days per year for 4 year, equating to one semester missed”) Describe key characteristics of the instruction the student has received in area of concern o Research based? Mention specific curricula, if known. o Amount/intensity? o Training of instructor (certified? IA?) o Size of group Section 4: The student does not have another disability or sensory problem. Report results of current vision and hearing screenings. Report historical difficulties with vision and hearing as reported by parent (infections, tubes, surgeries) Have there ever been suspicions of other disabilities? If so, what was done about them? Consider: o ADHD o Asperger’s o OHI o Communication o Emotional Disturbance o Mental Retardation If an IQ test was given, this is the place to note statistically unusual performance. Report results of evaluations done regarding any areas of concern raised at the time of referral or during the evaluation. o This is the place to explain, if you decided not to assess those areas, why you didn’t. OrRTI Guidance, September 2005 35 Source(s) Cumulative file Individual Problem Solving Worksheet Student Intervention Profile Parent Interview Report cards Teacher interviews Source(s) Cumulative file Individual Problem Solving Worksheet Parent Interview Report cards Teacher interviews Assessment results Minutes of Evaluation Planning Section 5: The student’s problem is not the result of cultural factors or environmental or economic disadvantage. Describe the student’s school history starting with preschool. Describe pertinent information about family literacy levels. Describe pertinent information about the family’s social history that could account for stressors, such as: o Frequent moves o Homelessness o Divorce o Unemployment o Extended illnesses or deaths in the family Section 6: The student’s problem is not the result of limited English proficiency. Identify the student’s primary and secondary languages. Report current levels of: o Primary Language Oral Proficiency o Primary Language Writing Proficiency o Primary Language Reading Proficiency o English Oral Proficiency o English Writing Proficiency o English Reading Proficiency How many years has the student lived in the US? And What is the home language? And What is the parents’ literacy proficiency? And What is a typical academic profile for a student with this language and family history? Section 7: Students with learning disabilities have academic skill deficits that are resistant to well-planned and implemented research based interventions. Relate interventions to the areas of concern as identified in the initial referral. State what the baseline skill level was (a number), and how that relates to the general population. State what the intervention was and the basis upon which it was chosen. Include: o Specific curriculum/method used o How much time and for how long, as well as a qualitative statement about the “size” of this intervention o Level and type of reinforcement used OrRTI Guidance, September 2005 36 Source(s) Cumulative file Individual Problem Solving Worksheet Parent Interview Source(s) Cumulative file Individual Problem Solving Worksheet Parent Interview LAS scores Source(s) Progress monitoring data Intervention group records Describe the student’s response to the intervention (a number), measured with the same assessment as the baseline data. o How does this relate to the general population? o How does this relate to progress of intervention group peers? Does this progress support a picture of a skill deficit that is resistant to instruction? Section 8: Is there sufficient evidence to support the conclusion that this student is eligible for special education as a student with a learning disability? This is the place that the “basis for determination” is stated clearly. Sources(s) Every component of the report in sections 1-8. Discussion of the team. Capacity Building It is imperative that a core group of district staff deeply understands current research on the identification of learning disabilities. The leadership team referred to earlier might serve to teach broader groups of teachers, specialists, and administrators. This team will need time to study and master issues around LD identification, reading instruction, and progress monitoring. Special educators must grasp the foundational underpinnings of RTI and the research from which they developed. Additionally, this group of staff will need training specifically targeting the transition from a discrepancy model to RTI – why is practice changing? This group’s level of understanding must be sufficient to support implementation of the RTI approach as well as explaining the approach to colleagues and parents. Many practitioners will need to review and discuss this information several times before they are comfortable with the core concepts. General educators require training on the same topics, though understanding need not be as comprehensive. The focus of training for this group is on the importance of early skill development and monitoring of that development, the redefined view of general education as providing first level interventions, and the need for collaboration. For some team members, this will require a fundamental change in the way part of their job is accomplished. For example, when IQ testing is not a routine part of each LD evaluation, school psychologists will play a very different role on a team. Their time may be used to conduct more targeted evaluations of attention or behavioral characteristics, consultation, or to assist with additional progress monitoring. OrRTI Guidance, September 2005 37 Where teaming is not a norm, deliberate planning for team formation and functioning is required. When a group is adopting both new practices and new ways of doing work, individuals may experience significant stress. A professional facilitator can help a team define its mission, establish norms, and improve skills like conflict management and negotiation. OrRTI Guidance, September 2005 38 Section Three Perspectives on Evaluation Models How do you know if a student has a learning disability? This question has intrigued and plagued educators, psychologists, and families for a quarter of a century. Numerous definitions have been promoted, with most of them having at their core the notions of specific and discrete processing difficulties that in turn cause unexpected underachievement. Educators, clinicians, and lawmakers have struggled, however, with finding a valid and reliable method of setting criteria that differentiate children with LD from other children who are low achieving. Following is a summary of some of the issues pertinent to the decision to include a new approach to LD evaluation in IDEA 2004. 1. What has the law required for LD eligibility? Although various definitions for LD have been promoted since the 1970’s, the codified definition of LD has remained essentially unchanged since 1977, when P.L. 94-142 was implemented. The term “specific learning disability” means a disorder in one or more of the psychological processes involved in understanding or in using language, spoken or written, which may manifest itself in an imperfect ability to listen, speak, read, write, spell, or to do mathematical calculations. The term includes such conditions as perceptual handicaps, brain injury, minimal brain dysfunction, dyslexia and developmental aphasia. The term does not include children who have learning disabilities which are primarily the result of visual, hearing, or motor handicaps, or mental retardation, or emotional disturbance, or of environmental, cultural, or economic disadvantage. (USOE, 1977, p. 65083) This definition has persisted, with minor organization and wording changes, through subsequent authorizations of IDEA. It is in the implementation of the definition through establishing eligibility criteria in federal regulations that the construct of discrepancy has been used: (a) A team may determine that a child has a specific learning disability if: (1) The child dopes not achieve commensurate with his or her age and ability levels in one or more of the areas listed in paragraph (a) (2) of this section, when provided with learning experiences appropriate for the child’s age and ability levels; and (2) The team finds that the child has a severe discrepancy between achievement and intellectual ability in one or more of the following areas: (i) Oral expression; (ii) Listening comprehension; (iii) Written expression; OrRTI Guidance, September 2005 39 (iv) Basic reading skill; (v) Reading comprehension; (vi) Mathematics calculation; or (vii) Mathematics reasoning (USOE, 1977, p 65083) Neither the Federal definition nor the criteria provide guidance on implementing the important exclusionary factors. Further, it is left to states to determine how to measure the severe discrepancy. The methods utilized by states include variations of simple discrepancy formulas in which IQ and achievement standard scores are compared, regression formulas which remedy measurement problems that exist due to correlations between IQ and achievement, differences in standard scores on academic achievement measures, percentage discrepancy, and professional judgment. Fourteen states, including Oregon, have left the method of determining severe discrepancy to individual school districts (Reschly et al., 2003). Oregon’s implementation of LD identification is located in administrative rules that describe evaluation procedures and criteria. Like all disability categories in Oregon, the regulations set out a definition which is consistent with federal law, a set of required evaluation activities and tools, and criteria that must be met if a team is to find a student eligible. Oregon’s criteria state that an eligibility team must determine that: A. The child does not achieve commensurate with his or her age and ability level in one or more of the areas listed (below). . . when provided with learning experiences appropriate for the child’s age and ability levels; B. The child has a severe discrepancy between intellectual ability and achievement in one or more of the following areas: (i) Oral expression; (ii) Listening comprehension; (iii) Written expression; (iv) Basic reading skills; (v) Reading comprehension; (vi) Mathematics calculation (when appropriate, includes general readiness skills); or (vii) Mathematics reasoning; and C. The child’s severe discrepancy between ability and achievement is not primarily the result of: (i.) A visual, hearing, or motor impairment; (ii) Mental retardation; (iii) Emotional disturbance; or (iv) Environmental, cultural, or economic disadvantage. OrRTI Guidance, September 2005 40 As in all other categories, the team must also determine that the disability has an adverse impact on the child’s educational performance (K-12) or the child’s developmental progress (age 3 to school age). 2. What events led to changes in LD identification in IDEA 2004? Through decades of educational practice, it has become generally accepted that a “severe discrepancy” is in fact a learning disability and—or—a proxy for a learning disability and its underlying processing disorders. It is now widely acknowledged that there is not a scientific basis for the use of a measured IQ achievement discrepancy as either a defining characteristic of or a marker for LD. Though numerous authorities (Fletcher et al., 1998; Lyon et al., 2001; Stanovich, 2005) have identified problems with discrepancy models, it has persisted as the most widely used diagnostic concept. In the 1997 reauthorization process, the concern with discrepancy approaches reached a head and the U.S. Office of Special Education Programs (OSEP) committed to a vigorous program of examining and summarizing evidence around LD identification. That effort resulted in the Learning Disabilities Summit (referred to in the introduction to this document), as well as subsequent roundtable meetings involving representatives of major professional organizations. While preparing for the 2004 IDEA reauthorization, OSEP conducted the 2002 Learning Disabilities Roundtable to generate a series of consensus statements about the field of learning disabilities. With respect to the use of discrepancy formulas, the members stated: Roundtable participants agree there is no evidence that ability-achievement discrepancy formulas can be applied in a consistent and educationally meaningful (i.e., reliable and valid) manner. They believe SLD eligibility should not be operationalized using ability-achievement discrepancy formulas (pg. 8). Other points of consensus from the Roundtable include: Identification should include a student-centered, comprehensive evaluation and problem-solving approach that ensures students who have a specific learning disability are efficiently identified (pg. 6). Decisions on eligibility must be made through an interdisciplinary team, using informed clinical judgment, directed by relevant data, and based on student needs and strengths (pg. 29). OrRTI Guidance, September 2005 41 3. What are major issues related to the use of the concept of discrepancy? Why change? Issue #1: Discrepancy models fail to differentiate between children who have LD and those who have academic achievement problems related to poor instruction, lack of experience, or other problems. It is generally agreed that the model of achievement-ability discrepancy that has been employed was influenced by research conducted by Rutter and Yule (1975) (Reschly, 2003). This research found two groups of low achieving readers, one with discrepancies and one without. It was this finding that formed the basis for the idea that a discrepancy was meaningful for both classification and treatment purposes. Later analyses of this research, and attempts to replicate it, have failed to produce support for the “two group” model for either purpose. In fact, it is now accepted that reading occurs in a normal distribution and that students with dyslexia or severe reading problems represent the lower end of that distribution (Fletcher et al., 2002). For a thorough discussion of this important issue, see Fletcher et al., 1998. Issue #2: Discrepancy models discriminate against certain groups of students: students outside of “mainstream” culture and students who are in the upper and lower ranges of IQ. Due to psychometric problems, discrepancy approaches tend to under-identify children at the lower end of the IQ range, and over-identify children at the upper end. This problem has been addressed by various formulas that correct for the regression to the mean that occurs when two correlated measures are used. However, using regression formulas does not address issues such as language and cultural bias in IQ tests, nor does it improve the classification function of a discrepancy model (Stuebing et al., 2002). Issue #3: Discrepancy models do not effectively predict which students will benefit from or respond differentially to instruction. The research around this issue has examined both progress and absolute outcomes for children with and without discrepancy, and has not supported the notion the two groups will respond differentially to instruction. (Stanovich, 2005) Poor readers with discrepancies and poor readers without discrepancies perform similarly on skills considered to be important to the development of reading skills (Gresham, 2002). Issue #4: The use of discrepancy models requires children to fail for a substantial period of time—usually years—before they are far enough behind to exhibit a discrepancy. In order for children to exhibit a discrepancy, two tests need to be administered—an IQ test, such as the Wechsler Intelligence Scale for Children, and an achievement test, such as a Woodcock Johnson Tests of Achievement. Because of limitations of achievement and IQ testing, discrepancies often do not “appear” until late second, third, or even fourth grade. Educators and parents have OrRTI Guidance, September 2005 42 experienced the frustration of knowing a child’s skills are not adequate and not typical of the child’s overall functioning, and being told to “wait a year” to re-refer the child. While waiting for a discrepancy to appear, other persistent problems associated with school failure develop such as poor self concept, compromised motivation, vocabulary deficits, and deficits associated with limited access to written content. Considering all of the methodological problems associated with discrepancy formulas, this feature is the one that is most problematic for parents and practitioners—so problematic, that by the late 1990’s the discrepancy approach was referred to as the “wait and fail” approach by federal officials. (Lyon, 2002) 4. If authorities believe underlying processing disorders are the cause of learning disabilities, why doesn’t IDEA 2004 include a model based on measuring processing problems? It is a relatively common practice for LD assessment to include descriptions of “processing” or “patterns of cognitive ability.” Frequently, the conclusions that are made are based on a student’s performance on subtests of intelligence measures, memory tests, and language evaluations. While interesting results may sometimes be produced, drawing conclusions about the presence of a disability based on such results is not substantiated by research. (Torgeson, 2002; Fletcher et al., 1998) Assessment of processing deficits in order to diagnose LD has a history even longer than that of discrepancy approaches. Indeed, frustration with the reliability and validity of processing assessment contributed to the proposal to use the severe discrepancy in LD criteria. (Hallahan and Mercer, 2002) The result was the inclusion of the concept of processing deficits in the federal definition of LD, but no criteria related to processing. There are clear advantages to this approach that make continued focus on processing variables attractive for both research and practice. Of particular importance is the concept that, if direct assessment of intrinsic processing was possible, so might be early and intensive preventative education that would avoid the associated pitfalls of school failure. Research in processing measurement continues at the neurological, cognitive or psychological, and task oriented level. Various authors continue to examine variables such as rapid naming (Cardoso-Martins and Pennington, 2004), working memory (Swanson, 1999), and temporal processing (Tallal, 1996). Unfortunately, difficulties inherent in this research have limited its practical application. Torgeson (2002) summarizes these difficulties: Any deficit in academic outcome or performance that fits the definition of a learning disability always involves a complex mixture of a processing weakness (or weaknesses) present at some point in development OrRTI Guidance, September 2005 43 (perhaps not even concurrently present), an instructional context in which the processing weakness operates, the child’ motivational and emotional reaction to the learning difficulties caused by the processing weakness, and the domain-specific knowledge acquired to support performance on the task. (p. 589) In other words, it is not possible to separate out all of the complicated factors that contribute to a child’s performance on tasks and make the assumption that an intrinsic cognitive process is being measured. While there may be promising research underway, a methodology for discrete diagnosis or classification based on processing differences is unavailable and certainly could not be included in LD criteria. At this time, it is probably appropriate to follow the advice of McGrady (2002) and continue a research program for assessment of intrinsic processes independent of school practice. 5. Are there other indicators of LD that are more valid and reliable? Generally, attempts to reliably define and measure psychological processing difficulties have yielded limited results that render them without practical application. However, related to this research, certain skills have been identified as robust predictors of academic performance. These skills may be characterized as “critical indicators” or “marker variables.” When embracing this approach, one accepts that the indicator may represent both constitutional and learned skills, and that the variable represents an important capability. Using this approach, researchers have identified measures of phonological awareness and early literacy knowledge such as letter sound relationships as powerful early predictors of later reading performance. (Good and Kaminski, 2002) Similarly, fluent reading of connected text continues to be highly correlated with growth in both word reading and comprehension, and represents meaningful ways to screen and progress monitor in reading. (Fuchs and Fuchs, 1998) Using this approach provides a method of screening to identify students with potentially persistent academic problems, and assessing them further. Fortunately, these variables have been identified for the most prevalent of school identified learning disabilities, those in the area of reading. Similar measures for domains such as math reasoning, calculation, and written language have not been as thoroughly investigated. Use of these indicators is a key practice that underlies the response to intervention (RTI) approach. 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OrRTI Guidance, September 2005 49 OrRTI Guidance, September 2005 50 OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Response to Intervention Readiness Checklist 8/11/05 Is your district ready to adopt a Response to Intervention (RTI) model for the identification of learning disabilities? This checklist is provided to assist in answering that question. Designed to guide a group of district leaders through an appraisal of prerequisite requirements, the completed Checklist must be submitted to the Oregon Department of Education (ODE) by all districts no later than November 15, 2005. Key systemic areas addressed through the checklist are: Leadership Teaming Curriculum Screening District Name: ___________________________________ Date: _______________ Primary Contact for Learning Disabled (LD) Identification Issues: ____________________________________ __________ ____________________ Name/Title E-mail Phone Staff Completing the Checklist: ____________________________________ ________________________________ Name/Title Name/Title ____________________________________ ________________________________ Name/Title Name/Title ____________________________________ ________________________________ Name/Title RTI Readiness Checklist Name/Title Sept. 2005 51 OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Leadership Established Willing to Implement District level support at the highest levels, including agreement to adopt an RTI model and allocate required resources Understanding of and commitment to a long term change process (3 or more years) Long term commitment of resources (staff, time and materials) for screening, assessment, and interventions District leadership team with basic knowledge of the research relative to RTI and the desire to learn more Expertise at the district level with respect to research based practices for academics and behavior Narrative: For “Established” items documented in the space below include specific information related to the involvement of the School Board, Central Office Administrators, and Principals. (Use additional space as necessary.) Narrative: For “Willing to Implement” items, describe current conditions that would support change in each area. (Use additional space as necessary.) RTI Readiness Checklist Sept. 2005 52 No OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Teaming Established Willing to Implement No Commitment to collaborative teaming (general and special education) at both the district and school levels Principal leadership and staff (general and special education) willing to participate at each school Willingness for general education, special education, and compensatory programs to work together at both the district and school levels Narrative: For “Established” items documented in the space below include specific information related to teaming structures currently in place at the district and school levels and specific initiatives that involve collaboration between general education, special education and compensatory programs. (Use additional space as necessary.) Narrative: For “Willing to Implement” items, describe current conditions that would support change in each area. (Use additional space as necessary.) RTI Readiness Checklist Sept. 2005 53 OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Curriculum Established Willing to Implement No Use of a research validated core reading program at each elementary school Use of or ability to acquire supplemental intervention materials Capacity to provide ongoing training and support to ensure fidelity of implementation Narrative: For “Established” items documented in the space below list the core reading program(s) adopted by the district, any supplemental intervention materials currently in use, and systems in place to provide training related to their implementation. (Use additional space as necessary.) Narrative: For “Willing to Implement” items, describe current conditions that would support change in each area. Include possible options for funding additional curricular materials that may be necessary. (Use additional space as necessary.) RTI Readiness Checklist Sept. 2005 54 OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Screening Established Willing to Implement No School-wide structures in place to facilitate systematic review of and programming to enhance student performance (examples: EBS, PBS, or EBIS)* Established student level data collection and management system that is tied to the content (example: DIBELS)* Capacity to implement progress monitoring Narrative: For “Established” items in the space below describe the data collection and management system used by the district, including details about the current progress monitoring system and calendar. (Use additional space as necessary.) Narrative: For “Willing to Implement” items, describe current conditions that would support change in each area. (Use additional space as necessary.) *Examples: EBS=Effective Behavioral Support PBS= Positive Behavioral Support EBIS= Effective Behavioral and Instructional Support DIBELS= Dynamic Indicators of Basic Early Literacy Skills RTI Readiness Checklist Sept. 2005 55 OREGON DEPARTMENT OF EDUCATION OFFICE OF STUDENT LEARNING & PARTNERSHIPS Summary Statement (check one): _____ Yes, after review of our responses on the completed Readiness Checklist, our district is applying to be included in the OrRTI Guided Development Project beginning in January 2006. Our completed Readiness Checklist, submitted prior to November 15, 2005, serves as our application to ODE. _____ After review of our responses on the completed Readiness Checklist, our district is moving ahead with implementation of the Response to Intervention approach to LD Identification. While we are not applying to be part of the OrRTI Guided Development Project, we understand that implementation of the RTI model will be a focus of audits included as part of the Systems Performance Review & Improvement (SPR&I) process. Our completed Readiness Checklist, submitted prior to November 15, 2005, serves as our notification to ODE. _____ No, After review of our responses on the completed Readiness Checklist, our district has identified system requirements which need to be in place before we adopt the Response to Intervention approach to LD Identification. Superintendent Signature Date Director of Special Education Signature Date Return to: Tricia Clair, Coordinator, Statewide Monitoring System Oregon Department of Education – OSL&P 255 Capitol St. NE Salem, Oregon 97310-0205 Completed Checklists must be submitted to ODE no later than November 15, 2005. RTI Readiness Checklist Sept. 2005 56