Beginning with the Whole Mind

Florida’s Systems Approach to Response to Intervention

The Florida Department of Education’s mission to increase the proficiency of all students within one seamless, efficient system is reflected in its intentional and coordinated use of a multi-tier system of supports (MTSS) framework across numerous state initiatives—all designed to improve the capacity of districts in the state to support higher levels of learning for all children, including those receiving special education services.

Each of Florida’s 67 counties includes a public school district. Home to more than two and a half million school-age students, 5 of the 10 largest school districts in the United States are located in Florida. At the same time, approximately 60% of Florida’s districts are small and rural, with 11 districts serving fewer than 2,600 students. Notably, the student population in Florida ranges from 966 students in the smallest district to over 356,000 in the largest district.


photo_fla_01In a large state with a high degree of diversity, effective partnerships between the state education agency (i.e., the Florida Department of Education) and organizations with high levels of expertise are essential for sustaining and scaling improvements on a statewide basis. One such partnership is the Student Support Services Project implemented collaboratively with the University of South Florida. Headed by Project Director George Batsche, this project and others—such as the Problem Solving/Response to Intervention (PS/RtI) Project and the Florida Positive Behavior Support Project—combine to provide the foundation for the state’s efforts to alter significantly ways that districts statewide assess and support children with a variety of disabilities and learning difficulties.


Total School-age Student Population: 2,720,074

Total School-age Special Education Student Population: 350,478

Total SLD School-age Student Population: 133,323

Percentage of Students with Disabilities Identified as SLD: About 38%

Number of Local Education Agencies: 67

Whereas the Problem Solving/RtI Project and the Florida Positive Behavior Support Project are primarily housed at the University of South Florida, the Student Support Services Project is situated within the Florida Department of Education (FDOE). “We are uniquely positioned to support multiple bureaus and so we function in large part as a unit of the Department of Education,” explained Heather Diamond, coordinator of the Student Support Services Project.

Diamond, school psychology consultant David Wheeler, and other project consultants work closely with Florida’s Bureau of Exceptional Education and Student Services and actually compose the student services component of the bureau. Diamond began her career with the state in 2005 as the specialist for specific learning disabilities. Similarly, Wheeler began as the school psychology consultant in 2006.

Common Vocabulary, Constant Communication


Embedding expert personnel, like Diamond and Wheeler, and focusing their work in a way that “enables the Florida Department of Education to be much more impactful around targeted initiatives like RtI/MTSS, and having them housed in the state education agency physically is a very unique opportunity to ensure common language, common understanding, transparency, and open communication” said Batsche.


The use of RtI/MTSS as a foundation for the implementation of all major state initiatives requires constant communication between and among state-level offices, and between the state and other partners (e.g., parents/families, regional offices, districts). At its inception it also required a move away from isolated implementation of initiatives to an integrated approach wherein MTSS serves as the basis for all broad-based initiatives. This integrated approach links initiatives across the state, such as Florida’s Race to the Top grant, differentiated accountability, standards-based instruction, and teacher/leader proficiency. The FDOE explains the need for an integrated—indeed a unified—system:

Education initiatives share common core elements and goals for all Florida schools. Historically, however, they are each facilitated by different offices within the DoE that address specific content areas or stakeholder groups. Each set of efforts has been built upon common elements, but with single-purpose resources and in segregated activities. Each separate effort also involved a unique set of terminology, professional development requirements, and data collection and reporting systems, which resulted in district and school personnel perceiving that an overwhelming number of parallel initiatives were either required or encouraged.” (Florida’s MTSS at

The most significant factor driving educational reform is the focus on outcomes for all students and not just those being considered for services through IDEA. Within this framework, the core question becomes "What do we want students to know and be able to do?"

SOURCE: Florida Department of Education. (2011). Guiding Tools for Instructional Problem Solving (GTIPS), p. 19.

“Logistics of a brave new world,” is how Batsche describes the process of bringing the pieces together to support system-wide changes in keeping with Florida’s vision of a unified approach. “From the beginning, we wanted to ensure that everything we did to improve academic and behavioral outcomes was required for all students; focusing on the use of RtI to determine eligibility for services as a student with specific learning disabilities (SLD) without having a larger context is not helpful,” he added.


An RtI framework is defined by FDOE as the “multi-tiered practice of providing high-quality instruction and intervention matched to student needs using learning rate over time and level of performance to make important instructional decisions.” (FDOE, 2011, p. 98). Moreover, it is the position of the FDOE that this practice represents a logic supporting a set of core beliefs. Key to this logic is the systematic use of a problem-solving process that must be integrated seamlessly into school improvement plans, student progression plans, K–12 comprehensive reading plans, differentiated accountability plans, and so on. “This problem-solving process must be applied to all learners, which includes general education students from pre-K through graduation, students with disabilities, and advanced and gifted learners… “(FDOE, 2011, p. 14).

Using a PS-RtI–Based Identification Process


Reflecting this new logic, school districts in Florida now must use a problem-solving process to determine how a student responds to scientific, research-based interventions (PS-RtI) when determining whether that student is, or continues to be, eligible for special education (FDOE, 2011). With the whole system in mind, however, the FDOE did not limit RtI to children with suspected learning disabilities. Instead, it uses the process for eligibility determination for children with suspected emotional and behavioral disabilities, and as the basis for eligibility for services to address language impairments. “We’re the only state that has gone beyond SLD and that is, in part, because our whole infrastructure is based on data-based decision making,” explained Batsche.

rti_comparison-to-discrepancy-model_vennIn fact, Florida’s commitment to using a data-based decision-making process and an integrated MTSS was “from the beginning a general education initiative that pre-dated the 2006 regulations1 for SLD,” according to Batsche.

Wheeler, who has been instrumental in FDOE’s development of state rules, policies, and procedures, concurs, noting “we see RtI as something that applies to all students, but in each of the rules that we developed we included the importance of monitoring student progress and providing evidence-based intervention. So that thinking really permeates all of our rules as well as our general education intervention procedures that are required for any student who is struggling academically or behaviorally as part of what general education is obligated to provide in terms of supports.”

Identification of students as students with SLD


Since December 2008, the FDOE required the use of a PS-RtI process as part of its general education intervention process (see Rule 6A-6.0331), mandating that this process be used prior to considerations of eligibility for special education. Soon thereafter, the FDOE’s SLD eligibility rule went into effect. The changed rules incorporated a transition period allowing districts to permit identified schools to continue to require a pattern of strengths and weaknesses—including an ability–achievement discrepancy—in making eligibility determinations until July 1, 2010.

“About 20 districts opted to begin using the new process out of the chute and the remaining 47 districts took additional time,” recollected Batsche. The transition period was intended to allow districts the time to prepare by building the capacity of their personnel to implement the new process.

Under Florida’s rule (see Rule 6A-6.03018 Exceptional Education Eligibility for Students With Specific Learning Disabilities), the traditional wait-to-fail model that begins with the question, “Is this student eligible?” has been replaced with the ongoing implementation of interventions matched to student needs, regardless of whether the student is eligible for special education services. Determining the services to be provided to a student after an eligibility determination has been made is now the last question that teams ask. Documenting a determination of eligibility for special education services as a student with SLD—as evidenced by RtI data—must confirm:


(1) A performance discrepancy—the student’s academic performance is significantly discrepant for the chronological age or grade level in which the student is enrolled, based on multiple sources of data when compared to multiple groups, which include the peer subgroup, classroom, school, district, and state level comparison group;

(2) Rate of progress—when provided with well-delivered scientific, research-based general education instruction and interventions of reasonable intensity and duration with evidence of implementation fidelity, the student’s rate of progress is insufficient or requires sustained and substantial effort to close the achievement gap with typical peers or academic expectations for the chronological age or grade level in which the student is currently enrolled; and

(3) Educational need—the student continues to need interventions that significantly differ in intensity and duration from what can be provided solely through general education resources to make or maintain sufficient progress.

questionable-response_graphIn determining an insufficient rate of progress, districts are provided decision rules that describe three levels of student response—positive, questionable, and poor—and decisions regarding next steps that can be made in accordance with those levels. A positive response to intervention is evidenced when the rate of student learning is such that the gap between expected student performance and current student performance is closing and the point at which the student’s performance will come in range of target can be extrapolated. A questionable response is indicated when the gap stops widening but eventual closure is not predicted; a poor response occurs when there is little to no change in rate of student growth after implementation of an agreed-upon intervention (FDOE, 2009, pp. 20, 25).


“In Florida, our progress-monitoring tools are developed with an eye to predicting and aligning with performance on high-stakes assessments aligned with the Florida standards,” said Batsche. Teams use a variety of data from multiple sources, such as state assessment, the Dynamic Indicators of Basic Early Literacy Skills (DIBELS), Florida Assessments for Instruction in Reading (FAIR), grades, classroom assessment, discipline referral data, formative assessment, and so on, to monitor the rate of growth, which is defined as the growth per week or month necessary to close the gap; an evidence-based intervention (EBI) is any intervention that results in the desired rate (Batsche, 2014). 


photo_fla_03For the RtI/MTSS process to work well, measures for monitoring progress and other assessments (e.g., periodic assessments) need to be aligned with measures of end-of-year performance. In other words, results on assessments of short-term gains ought to be good predictors of results on the end-of-year tests. To that end, the new FAIR—developed by the Florida Center for Reading Research in collaboration with Just Read, Florida! —provides teachers with screening, diagnostic, and progress-monitoring information that supports focused instructional decision making. Batsche explains: “One of the metrics in the new test is something called a PRS, which stands for probability of reading success. So every time an assessment is administered, whether it’s screening, benchmark, or progress monitoring, there’s an opportunity to get a PRS score with information on the probability of whether the student will pass the high-stakes assessment at the end of the year.”


Under the RTI process, failure is not required.  You don't have to fail to be eligible."

Dr. David Wheeler, School Psychology Consultant, Student Support services Project, FDOE/University of South Florida

“Traditionally, if a child didn’t have a discrepancy, he or she would have to fail in order to be eligible for services; failure is no longer required,” observed Wheeler. “We conceptualized eligibility as something that resulted from the need to sustain intensive supports and intervention over a period of time for the child to make progress,” he added. “We talk to people about needing to use their data to do a gradual reduction or fading of the intensity of support needed to see if the student maintains the rate of progress. Ideally, the team would consider eligibility knowing a child requires a very intensive level of support to be sustained over time, and knowing exactly what the student needs in order to maintain progress,” stated Diamond.

Wheeler and Diamond used the federal definition for “full and individual” evaluations to help district personnel understand that evaluations must be comprehensive enough to identify all of a student’s special education and related services needs. This return to the fundamentals of IDEA helped reframe the intent of the regulations—away from the notion that comprehensiveness relates to the scope of a battery of tests and toward a renewed understanding that comprehensiveness relates to what the child needs, the resources that will support the child’s learning, and the level of support that will contribute to his or her success.

Rate of Identification


Over the past 6 years, from 2006–2007 to 2012–2013, the number of school-age students identified with SLD in Florida has steadily declined from 176,939 to 133,323, representing a decrease of more than 20% ( With the exception of the disability category of autism, this trend is reflective of a general reduction in the identification of children as children with disabilities in Florida. Project personnel hypothesize that referrals for special education decrease when schools have and make use of supports that enable all students to be successful, and they view a reduction in the referral rate as a positive indicator, especially when that reduction is coupled with improvements in student achievement for students with and without disabilities.

Those improvements are evident in special education graduation rates, proficiency levels on statewide assessments, and results from the most recent administration of the National Assessment of Educational Progress (NAEP).1 For example, in May 2014, the FDOE reported that 12th grade Hispanic students' average NAEP scores in reading were significantly higher than those for Hispanic students across the nation, and the percentage of Florida's Hispanic students scoring at or above "Proficient" in reading was the highest of the 10 states that had sizable Hispanic populations.




In June 2014, U.S. Secretary of Education Arne Duncan described the use of multiple measures, including NAEP data, to measure not only procedural compliance, but also how students are actually performing. Based on the system used by the US Department of Education in rating state education agencies, Florida is one of only 18 states and territories to meet requirements. “We believe these outcomes to be a result of our comprehensive system of supports, which allow all students to access effective instruction and interventions,” said Diamond.

“Special education referral is triggered by lack of success,” said Batsche. “We have never used and we reject the concept of reductions in special education as an indicator of effective RtI. You have to combine student growth data with your placement data to make sure you haven’t left kids sitting at the corner,” he added. 


Building on a Strong Foundation:  From RtI to MTSS

While a strong foundation for the use of RtI in Florida pre-dated the 2004 reauthorization of IDEA, the development of a new process for determining special education eligibility provided the impetus for bringing a variety of stakeholder groups together in pursuit of a systems approach to improvement. One outgrowth of this work was the development of a statewide implementation plan supported by Florida’s Commissioner of Education. Another was the establishment of a family and community engagement work group, which developed, in collaboration with the FDOE’s Family and Community Outreach Bureau, a clear conceptual model and user-friendly products (e.g., video) to support meaningful parent and family engagement in the work.

So, when people ask, "Who within FDOE is responsible for RtI/MTSS" we say 'everybody'"

Dr. George Batsche, Professor and Director, Institute for School Reform, University of South Florida

As the work evolved, it became clear that some educators misconstrued RtI as another name for referral to special education. “We realized that we needed to redefine the larger work as being about a multi-tier system of supports,” explained Diamond. Another impetus for moving from RtI to MTSS involved the need to focus on both academics and behavior. “The preponderance of the literature clearly has established the strong relationship between instructional strategies focused on academics and instructional strategies focused on student engagement,” said Batsche. “The greatest amount of student growth occurs when both the instructional and the engagement strategies are integrated and planned for together,” he added.



Florida’s MTSS model targets districts, not schools, as the unit of change, while also supporting the work of school-based site teams and using pilot schools to validate the scale-up process and develop implementation progress-monitoring tools. “Our work is about increasing the district’s capacity to improve itself,” commented Batsche. A tiered model for differentiating support for districts is also used at the state level. “When we look at districts and the performance of students with disabilities, for example, we frame our thinking in support for those districts around a tiered support system by asking, ‘What is it that all districts need in terms of information, technical assistance, guidance? Which districts need much more support and how do we provide it?’” said Wheeler.

The commitment to what Wheeler calls “practicing what we preach” is evident in the use of MTSS across Bureaus within the FDOE. For example, MTSS is used by the Bureau of Student Achievement and School Improvement as part of differentiated accountability in its work to support district and school improvement. “The basis of school improvement in Florida is organized around a multi-tiered system of supports,” observed Batsche. The use of data-based problem solving and MTSS as a delivery system are required elements of school improvement plans (SIPs) and district improvement and assistance plans (DIAPs) in Florida. Beginning in September 2014, these plans will be monitored electronically by the Bureau of Student Achievement and School Improvement for compliance, integrity, and outcomes. Similarly, the Bureau of Exceptional Education and Student Services conducts monitoring focused on targeted assistance, and offices within the FDOE are working together to create a coordinated monitoring and support system using problem-solving assistance teams for providing support to districts with targeted needs.

fl-ps-rti-graphicThe process of using an MTSS framework for providing consistent support to districts is aided by state and regional structures (e.g., five regional centers under differentiated accountability, an MTSS Statewide Leadership Group, MTSS regional consultants and liaisons) that promote efforts to provide high-quality professional development and technical assistance to districts in the consistent use of MTSS to improve results for all children. An extensive array of implementation protocols (e.g., the Self-Assessment Problem-Solving Implementation [SAPSI] tool, the Self-Assessment of Multi-tier Systems of Support [SAM] tool) supports these efforts. “Currently districts monitor their level of implementation with the SAPSI, but that will transition next spring to the SAM,” explained Batsche.

The use of the MTSS framework is also embedded in the state’s new State Board of Education–adopted personnel evaluation system. The FDOE’s Bureau of Educator Quality organized the evaluation model, including its observation system, around MTSS. This development is especially important because implementation of an MTSS gives educators an effective tool for accelerating student growth, the demonstration of which counts for one half of a teacher’s evaluation.

Challenges, Accomplishments, and Next Steps

_dsc0373Whole system reform of the kind Florida has undertaken is never easy, but it is possible. Among the challenges identified by Batsche, Diamond, and Wheeler are (1) persistence: consistent and repetitive messaging about the core features of the RtI/MTSS work; (2) adaptability: constant readjustment to show connections between RtI/MTSS and new state initiatives or policies; (3) leadership: ongoing focus and mobilization of personnel to keep the work moving forward; (4) problem solving: efforts to break down perceived barriers (e.g., inflexibility around funding, changing roles); (5) capacity-building: supports that enable educators to get better and better at using data; and (6) clear messaging: frequent feedback to the larger education system reminding educators and policy makers that some children don’t fit the mold by “responding to 330 minutes of instruction at a level of proficiency.” According to Batsche, “Not all come to school with the same needs and as long as everything’s going well and you’re not collecting data, the negative consequences for students are minimal. But for the kids who are not doing well, if you’re not collecting data and you don’t know what’s happening and you don’t do something about it, the social consequences are abysmal.”

Despite the challenges, “we have fewer and fewer of those students that were just instructional casualties,” said Batsche. Part of our ongoing struggle involves reframing special education so that it can meet the needs of the students we’re now identifying that have more intense needs,” said Batsche. But the relationship between the use of MTSS as a systems improvement framework and the beliefs educators hold about the ability of all children to learn at higher levels is yielding positive changes. Wheeler recounts that “when we first started this process, 54% of all educators responding to a belief survey said they did not believe students with learning disabilities could achieve state standards. After 3 years of exposure to the training, that response dropped to about 20%.” “We have pretty strong evidence that expectations can be changed,” added Batsche.

Diamond noted that because of the work of the project, “we’ve come a long way in breaking down silos and in helping people think and work in teams more often and more deeply than they did even 5 years ago.”

The Florida team’s advice to other state education agencies (SEAs) that wish to use RtI/MTSS to improve student results is first and foremost, “practice what you preach.” “Ask the question: are we demonstrating all the behaviors that we are promoting at the district and school levels?” said Diamond. Other advice includes (1) making sure a strong evaluation plan is in place before embarking on the change process; (2) aligning state regulations and policies to support and allow for implementation; (3) targeting districts, not schools, and infusing the use of MTSS into state processes that affect all districts, such as district and school improvement plans; and (4) refraining from being overly prescriptive and instead promoting a way of thinking that allows district and school teams to make better decisions.

Batsche credits the National Association of State Directors of Special Education (NASDSE) and the organization’s original work to develop RtI “blueprints” for districts and SEAs for helping Florida move forward in adopting and adapting the RtI/MTSS framework in support of statewide improvement. Gathering together with other MTSS innovators also helped the Florida team. “When you’re in the midst of transition and introducing new ideas that not everyone understands or buys into, it’s really helpful to engage with others who are on a similar mission. It helps calibrate and encourage, and provide an opportunity to learn from each other’s experiences,” explained Batsche.

Florida’s work is not done. To the contrary, an expansion of the Guiding Tools for Instructional Problem Solving (GTIPS) document is under way, which will include evaluation tools (e.g., SAM) and feedback loops to inform the state about the degree to which bureaus are providing supports matched to district needs and thereby promoting deeper implementation at the district level.

Batsche sums it up: “Our ongoing work is about increasing system capacity to use system-level problem solving to improve student outcomes.”

  For additional information about Florida’s RtI/MTSS framework, contact the following Student Support Services Project personnel: George Batsche, EdD, Professor and Director, Institute for School Reform, University of South Florida, at 813.974.9472 or via e-mail at; Heather Diamond, Coordinator, at 850.245.0925 or via e-mail at; or David Wheeler, PhD, School Psychology Consultant, at 850.245.7847 or via e-mail at Readers are also directed to Florida’s Multi-Tiered System of Supports website at


1 Regulations issued in 2006 followed the 2004 reauthorization of the federal Individuals with Disabilities Education Act (IDEA), allowing state education agencies to adopt criteria for identifying students as students with SLD using an RTI process.
2 NAEP, known as the nation’s report card, is the National Assessment of Educational Progress.



Batsche, G. M. (2014). Response to intervention: Accelerating achievement for ALL students. Illinois IEA Professional Development Workshop.

Castillo, J. M., Batsche, G. M., Curtis, M. J., Stockslager, K., March, A., & Minch, D. (2010). Problem solving/response to intervention evaluation tool technical assistance manual. Tampa, FL: University of South Florida.

Florida Department of Education. (2009). Technical assistance paper. Questions and answers: State Board of Education Rule 6A-6.03018, Florida Administrative Code, Exceptional Student Education Eligibility for Students with Specific Learning Disabilities. Tallahassee, FL: Author.

Florida Department of Education. (2011). Guiding tools for instructional problem solving (GTIPS). Tallahassee, FL: Author.



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