Although changing the language of the gifted regulations to align with the IEP/ Special Education language makes sense in theory, it does not work in practice.  Reasons for this should be obvious.  There are fewer staff to work in gifted resource capacity, less money for programs that serve gifted students, and different requirements for evaluation.  For example, changing 60 instructional days to evaluate a student once referred to 60 days to evaluate would be problematic for 10 month employees if the student is referred during the last few days of school.

In short, making gifted regulation align with special ed./IEP language is a force fit and is hugely problematic.