Cricket, we were given the same interpretation of RTI for our kid. The school said that they would not qualify her for an IEP because she is at or above grade level in everything. They were willing to give her a 504 to allow her more time on tests (it was in their interest that she not totally bomb her CSAPs). When we presented our outside testing showing a large gap between achievement and IQ scores, they said that the achievement gap model is no longer recognized. I've reviewed the CDE's website and it seems to support this interpretation. Their interpretation of RTI only says that gifted kids who are high achievers need to be given more and kids who are failing need to be given more. If your kid tests as average, they don't seem to have to do anything. I haven't done any further research. I know other folks in CO who are getting the same story.