The Individual with Disability Educational Improvement Act (IDEA-2004) (P.L. 108-446) includes a policy called Early Intervening Services (EIS) which makes it permissible, but not mandatory, for a school district to use 15 percent of their IDEA Part B funds to provide services to non-disabled at risk students. However, a school district cited for disproportionality because of an overrepresentation of racial or ethnic minorities or second language learners receiving special education services or disciplinary action is "required" to use 15 percent of their special education funding to address these issues. The purpose of this study was to obtain knowledge on the impact of this IDEA policy at the local public school district level on the overidentification of students in general and specifically on the overrepresentation of African Americans in special education services. The design of the study utilized parallel case studies in six Northeast Ohio school districts. Three of these districts were cited for disproportionality and three districts were not cited for disproportionality. The design relied on two interviews in each district. Additional data was obtained from reviews of federal, state and school district records and relevant secondary sources. Four policy themes emerged from the Study: EIS policy was confusing because it lacked clarity on how disproportionality was determined; funding was punitive because it reduced funds for students with disabilities to provide interventions for general education students; implementation was unfair because some districts were required to establish EIS services and some were not; and the additional workload created for administrators was excessive. The three districts that used EIS funding to address a disproportionate number of African American students assigned to special education categories showed a reduction in disproportionality and were not cited after a year of EIS. However, the cause of this success was questioned because the benchmark for determining disproportionality was raised. All of the districts thought EIS could reduce overidentification, but only one reported a reduction of special educations students. [The dissertation citations contained here are published with the permission of ProQuest LLC. Further reproduction is prohibited without permission. Copies of dissertations may be obtained by Telephone (800) 1-800-521-0600. Web page: http://bibliotheek.ehb.be:2222/en-US/products/dissertations/individuals.shtml.]