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In this preregistered analysis, we aimed to descriptively investigate how different schools participating in a nationally-representative study implemented Response-to-Intervention (RtI) in 1st grade. We used public data N = 2,091 schools participating in wave 4 (1st grade) of the Early Childhood Longitudinal Study: Kindergarten Cohort of 2010-11 (ECLS-K: 2011). Results suggest that the largest discrepancies in RtI implementation across school contexts occurred between public and private schools. Private schools were more likely to rely on outdated special education eligibility determination methods and less likely to provide information about these methods to parents. Schools were also less likely to fully implement RtI if they served higher proportions of Black students, thus generating new hypotheses regarding the origins of special educational disparities.