standards. If not, a need for special education is indicated, and the student meets the second qualification for SLD. The process for ruling out other disabilities or conditions when using RTI is similar to that employed in other special education evaluations, and consists of procedures to ensure that sensory or intellectual disabilities or environmental disadvantage or cultural/linguistic differences are not the true cause of the student's assessed academic deficiencies. Establishing that the student's deficiencies are not the result of a lack of instruction, however, requires that the evaluation team document that the school has sufficiently provided good core instruction in the basic skills and robust interventions when students have failed to profit from typical instructional practices. The evaluation team must also show evidence that the school personnel conducted repeated assessments of the student's academic problems and communicated the results of those assessments to the student's parents. Schools that use a multi-tier system of support at a high degree of fidelity can typically readily rule out lack of instruction as a cause of the student's academic concerns. On the other hand, in enacting this provision, Congress was demonstrating a concern that students might be identified with a disability (SLD) when the actual cause of their academic failure was ineffective schooling. Identifying students with SLD in failing schools is arguably problematic. Response to RTI Criticisms point to delays in identifying students needing special education (which was also a concern in a 2010 OSERS Memorandum), difficulties in accurately determining the presence of a learning disability, and the amount of training needed by general education teachers. RTI can require additional work for teachers, and a potentially significant change in expectations represents a great source of resistance toward RTI. Another criticism of RTI is that while its core assumptions include "that the educational system can effectively teach all children," interpretations of the approach often do not account for gifted education. An inverted pyramid showing analogous increasing interventions for gifted children could be added to the model so that all children are addressed. A framework for such an approach has been developed by the Montana Office of Public Instruction. Concerns and criticisms of RTI for SLD classification Criticisms of the RTI model first surfaced in 2004 when IDEA identified it as a viable method for use in SLD eligibility determination Some feel that RTI is valuable for prevention, but see little empirical support for using RTI