The literature base on using formative assessment for instructional and intervention decisions is formidable, but the history of the practice of formative assessment is spotty. Even with the pressures of high-stakes accountability, its definition is fuzzy, its adoption is inconsistent, and the prognosis for future use is questionable. A historical and organizational perspective explores plausible explanations for that inconsistency. These possible explanations include the standard literature in the research-to-practice gap and must also include the current policy environment surrounding educational accountability. A number of organizational and historical/cultural hypotheses suggest potential limits of structured formative assessment. From several perspectives, the practical question that may shape the future of special education is the identity of individuals at the school level who are responsible for coordinating the collection of formative-assessment data, for analysis, and for responses to the data.