Response to Intervention as a Means to an End

Colorado’s Bold Action to Create a System of Education for All Children

In 2006, the Colorado Legislature revised its Exceptional Children’s Education Act (ECEA), mandating the use of Response to Intervention (RtI) and simultaneously prohibiting the use of a discrepancy-based 1 process for identifying children as having specific learning disabilities (SLD). This change in eligibility for special education services for children with SLD was seen as a radical move at the time, particularly for a state in which local control has been the norm. Former Assistant Commissioner and State Director of Special Education Dr. Ed Steinberg explained: “We took bold action, but knew from the beginning that for RtI to be effective on a larger scale, it could not ‘live’ in special education. Instead, it had to be seen as integral to improving student achievement.”

Now, eight years later, Coloradoco-photo1-edited Department of Education (CDE) personnel distinguish between an RtI-based SLD identification process and the state’s use of a Multi-Tier System of Supports (MTSS) framework, defined by Colorado as a whole-school, prevention-based framework for improving learning outcomes for every student through a layered continuum of evidence-based practices and systems.

“It is intended to be a systemic, continuous improvement framework in which data-based problem-solving and decision making is practiced across all levels of the educational system for supporting students” (Pereles, 2014). RtI is a process that is part of MTSS and, as such, relies on the effective use of assessment data to examine the interaction among instruction, curriculum, and environment that contributes to student success. Underlying both MTSS and RtI is the belief on the part of the CDE that all children can learn and achieve high standards as a result of effective teaching

Using an RtI-based SLD Identification Process

Colorado Quick Facts (2013-2014)
Total School-age Student Population: 876,999

Total School-age Special Education Student Population: 90,388

Total SLD School-age Student Population: 35,405

Percentage of Students with Disabilities Identified as SLD: About 39%

Number of Local Education Agencies: 178

RtI was initiated through and supported by the CDE’s Office of Exceptional Student Services when it was introduced to local school districts and other education service agencies in Colorado. By August 15, 2009, every administrative unit [i.e., districts, Boards of Cooperative Educational Services (BOCES), state operated programs] in Colorado was required to have implemented the revised SLD criteria and identification process. One year prior to this deadline, each administrative unit (AU) was required to submit to the CDE an implementation plan describing how it would implement the revised SLD criteria and identification process and, at the same time, address five key practices of RtI constituting a school-wide approach to improving instruction and student learning: (1) the problem-solving process; (2) curriculum, instruction, and intervention; (3) assessment/progress monitoring; (4) parent/family engagement; and (5) SLD determination. A self-assessment tool was developed by the CDE and made available to all AUs to assist them in the development of their plan. The CDE routinely monitors – as part of its cyclical review process – the degree to which districts and other education service agencies are making SLD eligibility determinations using the RtI process.

Dr. Deb LaQua, former school psychologist and now the Professional Development Coordinator for the San Juan BOCES in the far southwest corner of the state, noted that with an RtI-based SLD identification process, evaluation was “tied much more closely to what was happening in the classroom, and what teachers were seeing in the classroom. It can be more time consuming, but more effective; we’re not spending so much staff time doing work to establish eligibility that informs nothing.”


Shift in Identification of Specific Learning Disabilities

(As a result of IDEA 2004, Federal Regulations and the amended Colorado ECEA Rules)


Use of an RTI-based SLD identification process represents a fundamental shift away from a traditional “wait to fail” model whereby children had to experience serious academic difficulties before they were able to be tested. With the traditional model, intervention could be provided only after an assessment process, eligibility determination, and assignment of a disability label. With this approach, educators saw the source of an academic difficulty as inherent within the child; evidence of the child’s unexpected underachievement came from a comparison between the child’s achievement and a measure of his or her ability.

In contrast, RtI supports the provision of intervention at the first indication of a learning difficulty (CDE, 2011, p. 12). Instead of focusing on inherent student characteristics that are perceived to be unalterable, RtI emphasizes the instructional characteristics that are likely to improve academic outcomes (e.g., variations in instructional time, intensity, methods, and so on). With RtI, core instruction for all students can be augmented for some in order to improve learning processes and outcomes. Unexpected underachievement is determined by observing persistent difficulties in response to increasingly intensive instructional interventions (CDE, 2011, p. 12).

“We’ve shifted from focusing on ‘what students can’t do’ to what we need to do. Now, we’re much better at improving all students’ progress because we look at our whole system and what all children should learn,” explained Dr. Montina Romero, Director of Exceptional Student Services for the Fountain Fort Carson School District. Fountain Fort Carson serves about 8,000 children in 12 schools. Federally connected students2 comprise approximately 68 percent of the district’s total school population, contributing to a high rate of student mobility.

Identification of students as students with SLD


Colorado’s Guidelines for Identifying Students with Specific Learning Disabilities (2011, p. 52) state, “In identifying the existence of SLD, a determination must be made that a student continues to have a significant academic skill deficit even after obtaining evidence of effective instruction in the general education classroom and the provision of targeted and/or intensive intervention.”

Before referring a child for special education evaluation, the school-based problem-solving team should be able to describe the student’s performance in consideration of a number of conditions.




 Sufficient Progress


Benchmark - 90 / Current Level - 20 = 70 (gain needed to close the gap)
Intervention resulted in the 4.6 WPM growth per week necessary to close the gap with peers.

 Insufficient Progress

Benchmark - 90 / Current Level - 20 = 70 (gain needed to close the gap)
Intervention did not close the Gap - student needs more time, intensity or a different intervention.




For example, the team might address questions such as: To what degree does the student’s achievement and/or behavior differ significantly from that of other students with similar demographic characteristics? Has Tier 1 (core) instruction been effective with approximately 75 percent of students with similar demographics? Were selected interventions evidence-based or considered instructional best practice and have they been implemented as designed? Did the student benefit from any of the interventions? What evidence showed that the achievement gap between the student and grade-level peers was closing? What evidence indicated a significant achievement gap even after the implementation of targeted and/or intensive intervention? In order to benefit from the general education program, did the student need ongoing supports and services that could not be maintained through general education alone?

One method for determining a student’s level of progress involves a gap analysis that can be conducted using local norms, research-based norms, or criterion-referenced benchmarks. In conducting the gap analysis, the team first divides the expected benchmark by the student’s current performance (e.g., 68 words per minute divided by 20 words per minute = 3.4). A gap at or greater than 2.0 is considered to be significant. Next, the team determines the desired level and rate of progress by subtracting the student’s current performance from the expected benchmark in the next benchmark period (e.g., 90 words per minute minus 20 words per minute = 70 words per minute divided by the number of weeks for intervention = the weekly gain needed) (CDE, 2011, p. 55).

There is still some degree of disconnect between classroom assessment data and progress monitoring data. “We use curriculum-based measurement (CBM), such as AIMSweb, because we have normative data. And we don’t use the same evaluation method, CBM in this case, to address both parts of the eligibility criteria – academic gap and insufficient progress,” explained LaQua. “Teachers begin collecting CBM data at the first indication that a student is not making sufficient progress and the benefit is that we can identify children with learning disabilities much earlier – in kindergarten and first grade, for example – and at a time when we can most impact their learning. The best time to provide intensive intervention in reading is when children are just learning to read,” she added. “We’re trying to build the understanding that all data should be formative in nature,” said Romero. “Our system has a comprehensive understanding of assessment and all schools have expectations around formative and summative data use; in addition, all teachers engage in progress monitoring,” she added.


Focus on the System
To get to "all"
we must pay attention to "every"
We must pay attention
to the "System", first, and then,
we move to small groups and individuals.
--Dave Tilly

The CDE acknowledges that district and school personnel need to have a clear understanding of curriculum-based measures and must be able to use data to identify trends in student performance. “You have to have a certain level of sophistication to be able to monitor and graph data or at least chart them in a way that shows benefit or loss,” explained Randy Boyer, CDE Assistant Commissioner and State Director of Special Education. According to Boyer, ensuring that all students have an opportunity to learn, adjusting expectations so that all students are taught in relation to standards, and getting better at using relevant state and classroom assessment data as part of the RtI process are important in improving results for all students. “You start to see a pattern of disability popping up when students have not been exposed to or had an opportunity to learn academic content,” he said.

Rate of identification

Unlike most other states in the nation that have experienced a decrease in the rate of SLD identification over recent years, Colorado has experienced a slight, but steady increase in the number of school-age children identified as children with SLD – from 29,996 in 2006-2007 to 34,317 in 2012-2013 (source IDEA Data Center). At the same time, Colorado’s overall special education school-age child count shows a decrease of about 700 children with disabilities despite the fact that the state’s student enrollment has been growing at about two percent per year over the last 10 years.

“Special Education can't change the whole system by itself. It's got to be all hands on deck.”

Daphne Pereles - Executive Director, Office of Learning Supports, Department of Teaching & Learning, Colorado Department of Education


Having lower rates of SLD identification was not a goal of the CDE in requiring the use of an RtI-based identification process. “It’s not necessarily good or bad,” said Steinberg. The goal is to get the right kids in special education – the ones that truly have disabilities, as opposed to being instructional casualties,” he added. “When we first started using an RtI-based process, identification rates decreased a bit because the process was new,” explained LaQua. “However, now most children referred for special education as a student with SLD are found eligible for services because we have solid data to support eligibility.” Dr. Montina Romero, Director of Exceptional Student Services in the Fountain Fort Carson School District, agrees. “With the old model, it was hard to get to the point where we investigated enough to say we suspected a disability,” she said.

Unlike LaQua, and Romero who helped develop Colorado’s RtI guidelines, not all educators embraced the more comprehensive evaluation process required by RtI. As Boyer observed, “it’s fairly difficult to identify a student with a disability under an RtI structure. I saw many instances where a child could be found eligible in five days under a discrepancy model; you could go behind the curtain and come back and you’ve got an SLD label on you. There have to be benefits to the student because it’s harmful to put labels on children. If we’re going to do that, we dang well better be doing something for that child, no ifs, ands, or buts,” said Boyer.

“We encourage districts to avoid replacing one set of labels with another and to say, for example, ‘Suzie is receiving targeted remedial support for reading,’ rather than ‘Suzie is a yellow or red zone kid’,” explained Daphne Pereles, Executive Director of CDE’s Office of Learning Supports. “I’m entirely convinced that if we got the right instruction in early reading skills to children, we would have fewer referrals to special education because kids who are struggling and who are not really SLD would have their needs met through targeted instruction,” added Candy Myers, Supervisor in the Exceptional Student Services Unit and State Consultant for SLD.

RtI as Part of a System of Supports

The commitment to move beyond identification for special education services is reflected in CDE’s emphasis on MTSS as an instructional framework that can be used to foster higher levels of learning for all students. As Pereles, notes “it makes more sense to identify kids within the context of learning. If you’re not addressing the system by creating solid core instruction to support the RtI process, then it isn’t really going to matter.”


MTSS Teaming Framework     





Colorado has worked hard to reduce the disconnect between general education and special education – what some call “silos”. When Pereles joined the CDE eight years ago, RtI was housed within the Exceptional Student Services Unit. But, about four years ago, the work related to MTSS as an instructional framework, including positive behavioral interventions and supports (PBIS) and RtI, was reorganized under the Office of Learning Supports with Pereles at the helm – serving as a bridge between the Special Education Unit and the Teaching & Learning Unit. “It’s the responsibility of everyone in the Department to know about and have an understanding of RtI,” said Pereles.

Sustain investments, focus on implementation

MTSS is a data-driven, prevention-based framework for improving learning outcomes for every student. It integrates previously separate but similar initiatives (e.g., PBIS, RtI). Like other state RtI/MTSS models, the model used by the CDE emphasizes a set of core structures and practices (e.g., a layered continuum of supports, universal screening and progress monitoring, and so on). However, unlike many other models, Colorado’s model acknowledged the importance of the local district in sustaining any improvements made as a result of the use of MTSS.

Among the core principles adapted by the Colorado RtI Task Force and the Colorado RtI Implementation Team from the National Association of State Directors of Special Education’s 2005 document, Response to Intervention: Policy Consideration and Implementation, is the belief that effective leadership at all levels is crucial for the implementation of RtI. The recent focus on shared leadership, not only administrative support, is indicative of the CDE’s growing awareness that district-wide collaborative learning is necessary to improve learning for every child. “The problem with implementation has been the system,” remarked Pereles. “We’ve done a lot of work at the school level, but unless you have district leadership really understanding the work, it’s difficult to sustain when a principal leaves or gets promoted. That’s why we started this year, using the foundation of implementation science, focusing deeply on creating district-level teams to support their schools in meeting the needs of every child – it’s about sustainability more than anything and return on your investments,” she said.

CDE’s work to support district-wide continuous improvement is taking hold. Romero explains: “We don’t have a separate plan for how to educate children with disabilities; we’ve built a system that has a fundamental understanding that we can’t work separately and cannot have different philosophies and practices. At the school level, administrators are responsible for creating aligned systems; all teachers are part of data dialogue, there is non-negotiable universal instructional time for all kids, and everyone is invested in making decisions that benefit all children.” “We’re seeing the incorporation of MTSS to support the delivery of tiered instruction as part of the Unified Improvement Planning (UIP) process used by districts and schools. As a result, districts are asking BOCES for much more focused, targeted professional development and technical assistance in using MTSS to help them address identified needs, and to help principals address teacher areas of needed growth in more effectively meeting the instructional needs of all children aligned with the Colorado Teacher Evaluation System,” said LaQua.

Boyer agrees. “We can’t improve outcomes for students with SLD unless we have strong supports in all of our districts and this is kind of contrary to the history of special education. We’ve had our hand out saying ‘we’ll take them and we’ll send them back fixed.’ We know now that meaningful RtI implementation requires a platform of good solid instruction, of knowing what the needs are and then sorting out the interventions to match those needs,” he said. “It’s difficult to separate the RtI-based SLD identification process from MTSS; I struggle to talk about one without the other,” added Myers.

“RTI cannot stand on its own. SLD eligibility under RTI stands on the shoulders of effective core instruction”

Deb LaQua, Ph.D. - Professional Development Coordinator, San Juan BOCES.

The CDE advocates the development of aligned leadership teams at each level of the system for the purpose of ensuring effective implementation across all levels, including district, school, classroom, and individual student. The Colorado MTSS Teaming Framework facilitates the coordination of training, coaching, resource allocation, and evaluation to support the implementation of MTSS through shared decision-making by a group of individuals who represent the school, district, and community (Pereles, 2014). “We cannot create a system when we’re only focused on individual students; MTSS takes us out of the individual child mode into more of a system look at data about our district, how we break that down into data about our school, about groups of children, and about the individual student,” stated Pereles. Similarly, “you have to have district-level leadership – it’s a must and it has to be collective, not just from one person,” added Romero.

Challenges, Accomplishments, and Next Steps


Pereles, Boyer, and Myers agree that consistent statewide implementation of RtI within an MTSS framework continues to be a challenge. Inconsistencies in language, terminology, understanding of evidence-based practices, and use of the problem-solving process contribute to varied levels of implementation in districts across the state. “The technical skills of our personnel in the effective use of assessment data and how to interpret those data are lacking and it’s problematic,” said Boyer. Myers offered that the “leadership structure at every level of the system and getting the system aligned and connected are among the biggest barriers.”


Boyer and Myers cite the 2006 rule change, which required the use of the RtI-based SLD identification process as the biggest accomplishment since it “made RtI a non-negotiable in a local-controlled state.” colorado_readingFurther, Colorado’s use of a stakeholder group with varying perspectives and its reliance on meaningful partnerships with families – grounded in the belief that families are active partners – contributed greatly to the development of shared or collective ownership of the work. But, as LaQua points out, “just making a law doesn’t make it so. You have to provide the kind of ongoing support for staff that CDE has provided, and time for people new to the process to learn from those who are more experienced.”


Pereles regards the use of MTSS as an organizational framework for Colorado’s educational legislative priorities, and the integration of RtI practices and MTSS as part of the state-required UIP process as “value-adds.” “Increasingly, we see people connecting the dots and the real accomplishment is that we’re at that place where we can’t answer the question, ‘who does RtI’? Everybody does it,” she said. LaQua agrees that RtI must be viewed within the larger context of MTSS as an instructional framework. “RtI cannot stand on its own. SLD eligibility under RtI stands on the shoulders of effective core instruction. If you don’t have effective core instruction in general education, it looks like everyone needs special education and it’s a disservice to all children,” she said.


Immediate next steps for CDE’s Office of Special Education, according to Boyer, include “focusing on performance outcomes as part of our state systemic improvement plan, particularly since students with SLD are the most challenged performers in the state.” “We’re beefing up the continuous improvement process within each of our administrative units so that even more technical assistance is provided when there’s an indication that the system components (e.g., appropriate evaluations) are not in place,” said Myers. From Pereles’ perspective, “focusing on shared leadership and helping districts put teams together with adequate coaching support to sustain the schools” is the next major piece of work.


Boyer and Myers recommend that state personnel include practitioners in all aspects of the work and have their ear to the ground. “We’ve got to be instructionally based and prepare district and school personnel to be general educators first and special educators second; they have to have a whole concept of what disability is all about,” said Boyer.


Pereles advises other state education agencies that want to implement an effective RtI process within a MTSS framework fully to “really break down the silos within the department. We need to help people understand that once a child is identified as having a specific learning disability, they’re still part of the comprehensive system of supports and there’s still an expectation that they’ll make progress,” she said.


Or, as Steinberg advises, “don’t see RtI (or any other initiative) as an end in itself. Rather, it is a means to an end and that end is improved outcomes for all children.” 

  For additional information about Colorado’s MTSS framework, contact Daphne Pereles, Executive Director, Office of Learning Supports, Department of Teaching & Leaning, Colorado Department of Education, 201 E. Colfax Ave., Denver, CO 80203, 303-866-6622;

For more information about Colorado’s RtI-based SLD identification process, contact Candy Myers, Supervisor, Exceptional Student Services Unit and State Consultant for SLD, at 303-866-6883 or via email at; or Randy Boyer, Assistant Commissioner and State Director, Office of Special Education, Department of Programs & Supports, Colorado Department of Education at 303-866-4093.

For more information about support for effective implementation of RtI/MTSS provided by the San Juan BOCES, contact Deb LaQua, Ph.D., Professional Development Coordinator, at 970-247-3261 (x 124), or via email at:

For information about how RtI/MTSS is used at the local level, contact Montina Romero, Ph.D., Director of Exceptional Student Services, at (719) 382-1314, or via email at


1 Previous eligibility models relied on the identification of a discrepancy between students’ ability (i.e., IQ) and achievement (i.e., achievement test scores).

2 Federally connected children are children of armed services personnel working at the nearby Fort Carson military base. 




Colorado Department of Education. (2011). Guidelines for identifying students with SLD. Denver, CO: Author.


Pereles, D. (2014). Multi-tiered system of supports (MTSS): An overview. Denver: Colorado Department of Education, Office of Learning Supports.


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