Yes-- note that they are OFFERING HIM SERVICES/ACCOMMODATIONS.
Ask "where is this in his plan?"
They are trying (potentially, probably) to get around formal identification so that they aren't on the hook for anything that they don't feel like doing down the road.
Make them follow the process. Getting accommodations/interventions in place BEFORE identifying what his needs are (via the procedure that they've established for the school/district) is technically not kosher under the law. Just so that you know that.
Actually, it IS kosher and standard practice now. Response to Intervention (RtI) is supposed to be done with any student who struggles-- you differentiate and try to meet the needs, take data on what works, and then write that all into a plan so that you continue doing what has been established as actually helpful.
However: RtI is NOT allowed to be used to delay writing the plan. I'd use this as an occasion to ask them (in writing) to start a formal educational evaluation toward reconsidering an IEP, listing everything you're concerned about.
And thank them for seeing the need and offering the services in the meantime.
