Responsiveness to intervention (RTI) is being proposed as an alternative model for making decisions about the presence or absence of specific learning disability. We argue that many questions about RTI remain unanswered, and that radical changes in the proposed regulations are not warranted at this time. Since many fundamental issues related to RTI have not been resolved, a better strategy may be to more rigorously implement existing identification criteria (e.g., discrepancy and psychological processing deficits) in a structured psychometric framework. Suggestions for how to modify present procedures are provided.