Using an extant database, we examined three grade 1 criteria for identifying response to intervention (RTI) in English language learners (ELLs): (a) set benchmark criteria with a standard score above 95 (37th %ile) on both decoding and comprehension measures and a raw score of 40 or more correct words per minute (CWPM) on oral reading fluency; (b) discrepancy benchmark criteria, with performance on these measures at or above the mean of not-at-risk peers; and (c) discrepancy slope criteria, with growth during grade 1 on these measures at or above the mean of not-at-risk peers. The sample consisted of 81 students (41 intervention, 40 comparison) who were bilingual (Spanish/English) and were part of a supplemental reading instruction study during first grade. The three grade 1 criteria were evaluated in relation to a set benchmark criteria in grade 2. Results indicated that approximately 80% of the students did not meet any criteria in either year, but that the discrepancy slope criteria in grade 1 were most predictive of set benchmark criteria in grade 2. Recognizing that we applied highly stringent criteria, implications and issues are presented related to using RTI with ELLs to facilitate decision making about further intervention and referral for special education.