Have you gone through a few passages and asked him to answer the questions? If so, how does he do? Does he understand what's being asked?

When we asked for an IEP assessment for one of my kids, an entire team worked with us. A psychologist tested him, a speech therapist tested him, he was observed in the classroom, and we and his teacher had to attend meetings and fill out a detailed questionnaire. It seems odd that they'd base a decision like that on a single teacher's observations.

(A recent thread said that delaying testing or denying because of RTI is illegal under
federal law).