I see. One of the factors is that you are in an RTI state, where the emphasis is on performance compared to grade level expectations, rather than compared to individual expectations. Not all practitioners would end the process after grade-level achievement scores, but many would. So yes, it will likely be more challenging to get special education services.
In that case, I would request all testing records, and take them to a neuropsychologist for consult. Alternatively, if you have already been through a formal IEP eligibility process, wherein she was found not eligible, you can also dispute the finding, and request an independent educational evaluation, which would would have the advantage of being at district expense, but the disadvantage that you would have to pick from their list of approved providers, which gives you less control over who does the testing.