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With the 2004 revision of the Individuals with Disabilities Education Improvement Act (IDEA, 2004) came the promise of Response to Intervention (RTI) as a more equitable alternative to IQ-achievement disparity testing for identifying learning disabilities in U.S. K-12 public schools (Fuchs & Fuchs, 2006). RTI, also known as multi-tiered systems of supports, helps ensure that students have the opportunity to receive immediate, intensive, and short-term learning intervention prior to special education referral and is designed to help educators identify disabilities more accurately (Arden et al., 2017; Fuchs & Fuchs, 2007). However, in order for RTI to be effective for all students, it must carefully take linguistic and cultural differences into account (Klingner & Edwards, 2006; Park et al., 2017; Orosco & O’Connor, 2013). Persistent findings on disproportionality of English learners in special education placement via RTI is unquestionably an issue of educational equity (Linn & Hemmer, 2011; Skiba et al., 2008). Disproportionality of English learners identified for special education has been reported across disability types, grades, and locations (e.g., Artiles & Ortiz, 2002; Sullivan, 2011; Sullivan & Bal, 2013; Yamasaki & Luk, 2018). Some studies report over-representation (e.g. Sullivan, 2011), others under-representation (e.g., Artiles et al., 2005; Morgan et al., 2012, 2015, 2017), and others a shift in the disproportionality pattern, of under-representation in the primary grades and over-representation in the upper elementary and secondary grades (e.g., Hibel & Jasper, 2012; Samson & Lesaux, 2009; Umansky et al., 2017). As with all school reform, successful implementation of RTI requires interpretation of abstract policies at state and federal levels into concrete procedures at the local levels (Spillane et al., 2002). Yet, despite the significant implications of RTI outcomes for English learners, scant research attends to the perspectives of educators who do this interpretive work (Park 2019; 2020). Particularly absent from research are the voices of teachers in new immigrant destination regions, such as the American South (Gandara & Mordechay, 2017). In this study, we utilized interpretive phenomenological analysis (Smith & Osborne, 2003) of interview and focus group data collected with elementary and middle school educators (N = 9) who serve large numbers of English Learners at rural, suburban, and urban schools (N = 5) in a new immigrant destination region of the American South to better understand their perspectives of implementing RTI frameworks with English learners (see Table 1). We found that the teachers held divergent views about the appropriateness of special education referral for English learners, with some expressing concern that students are too often referred before they have time to attain English proficiency, and others expressing concern that RTI processes make it challenging for English learners to attain special education designation when they actually need it. These tensions are exacerbated by confusion over policies, lack of clarity about the purposes of English Language Development, and limited availability of appropriate measures, particularly assessments in languages other than English.