The goal of this report was to explore ways to differentiate the performance of early school-aged Spanish-English bilingual children in U.S. public schools, who appear “at-risk” for language impairment versus those who have true risk. We compared the patterns of performance reported for children with typical development and language impairment reported in the literature to those for children with risk described by Bedore et al., (2013) and Perez et al., (in preparation). Children with risk seem quite different than their peers with true language problems on formal measures such as the Bilingual English Spanish Assessment (BESA). However these children presented fewer errors or weaknesses in spontaneous speech than did their peers with true language impairment. Language variability and errors are expected in the language of young bilingual children, so it is of utmost importance that language professionals closely assess each of the child’s languages with formal and functional measures prior to making a diagnosis of language impairment.