Special Education Inclusion
This paper was written in 2001 by Katie Schultz Stout, WEAC's Director of Instruction and Professional
Development, and updated in 2007 by Joanne Huston, Teaching and Learning Consultant/ Legal Counsel
Posted March 15, 2007
Inclusion remains a controversial concept in education because it relates to educational and social values,
as well as to our sense of individual worth.
Any discussion about inclusion should address several important questions:
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Do we value all children equally?
What do we mean by "inclusion"?
Are there some children for whom "inclusion" is inappropriate?
There are advocates on both sides of the issue. James Kauffman of the University of Virginia views inclusion
as a policy driven by an unrealistic expectation that money will be saved. Furthermore, he argues that trying
to force all students into the inclusion mold is just as coercive and discriminatory as trying to force all
students into the mold of a special education class or residential institution.
On the other side are those who believe that all students belong in the regular education classroom, and that
"good" teachers are those who can meet the needs of all the students, regardless of what those needs may
be.
Between the two extremes are large groups of educators and parents who are confused by the concept
itself. They wonder whether inclusion is legally required and wonder what is best for children. They also
question what it is that schools and school personnel must do to meet the needs of children with disabilities.
While recognizing that there are no simple answers, this paper attempts to give an overview of the concept
of inclusion and offers a set of recommendations that can help to ensure that we meet the needs of all
students.
Definitions
In order to discuss the concept of inclusion, it is first necessary to have a common vocabulary. Research
Bulletin Number 11, 1993, from Phi Delta Kappa's Center for Evaluation, Development, and Research
provides a useful set of definitions. The following have been edited for clarity.
Mainstreaming
Generally, mainstreaming has been used to refer to the selective placement of special education students in
one or more "regular" education classes. Proponents of mainstreaming generally assume that a student
must "earn" his or her opportunity to be placed in regular classes by demonstrating an ability to "keep up"
with the work assigned by the regular classroom teacher. This concept is closely linked to traditional forms
of special education service delivery.
Inclusion
Inclusion is a term which expresses commitment to educate each child, to the maximum extent appropriate,
in the school and classroom he or she would otherwise attend. It involves bringing the support services to
the child (rather than moving the child to the services) and requires only that the child will benefit from being
in the class (rather than having to keep up with the other students). Proponents of inclusion generally favor
newer forms of education service delivery.
Full Inclusion
Full inclusion means that all students, regardless of handicapping condition or severity, will be in a regular
classroom/program full time. All services must be taken to the child in that setting.
In addition to problems related to definition, it also should be understood that there often is a philosophical or
conceptual distinction made between mainstreaming and inclusion. Those who support the idea of
mainstreaming believe that a child with disabilities first belongs in the special education environment and
that the child must earn his/her way into the regular education environment.
In contrast, those who support inclusion believe that the child always should begin in the regular
environment and be removed only when appropriate services cannot be provided in the regular classroom.
Does Federal Law Require Inclusion?
Two federal laws govern education of children with disabilities. Neither requires inclusion, but both require
that a significant effort be made to find an inclusive placement.
IDEA
The Individuals With Disabilities Education Act (IDEA), as amended in 2004, does not require inclusion.
Instead, the law requires that children with disabilities be educated in the "least restrictive environment
appropriate” to meet their “unique needs.” And the IDEA contemplates that the "least restrictive
environment" analysis will begin with placement the regular education classroom.
However, IDEA recognizes that it is not appropriate to place all children in the regular education classroom.
Therefore, the law requires school districts to have a “continuum of placements” available, extending from
the regular education classroom to residential settings, in order to accommodate the needs of all children
with disabilities. Using the continuum concept makes it more likely that each child would be placed
appropriately in an environment that is specifically suited to meet his/her needs. The law intends that the
degree of “inclusion” be driven by the student’s needs as determined by the IEP team, not by the district’s
convenience or the parents’ wishes.
In developing the Individual Education Program (IEP) for a child with disabilities, the IDEA requires the IEP
team to consider placement in the regular education classroom as the starting point in determining the
appropriate placement for the child. If the IEP team determines that the "least restrictive environment"
appropriate for a particular child is not the regular education classroom for all or part of the IEP, the IEP
team must include an explanation in the IEP as to why the regular education classroom is not appropriate.
The purpose of these requirements is to carry out the intent of the IDEA, which is to educate as many
students with disabilities as possible in the regular education classroom, while still meeting their unique,
individual needs. Robert T. Stafford, the Republican Senator from Vermont and one of the bill's primary
sponsors, has argued that the legislation is essential if we are to allow children with special needs to live
ordinary lives (Arnold and Dodge, 1994).
Section 504 of the Rehabilitation Act of 1973
Section 504 requires that a recipient of federal funds provide for the education of each qualified
handicapped person in its jurisdiction with persons who are not handicapped to the maximum extent
appropriate to the needs of the handicapped person.
A recipient is required to place a handicapped child in the regular educational environment unless it is
demonstrated by the recipient that the education in the regular environment with the use of supplementary
aides and services cannot be achieved satisfactorily.
Because the categories of disabilities covered by the IDEA have expanded during the past two
reauthorizations in 1997 and 2004, Section 504 is less frequently used to obtain access to public education
for students with disabilities.
Court decisions provide guidelines governing placement under IDEA
Even after several reauthorizations of IDEA, most recently in 2004, federal law leaves several questions
unanswered, including three significant ones:
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How far must schools go?
How important is potential academic achievement/social growth in making placement decisions?
What are the rights of the other children?
Guidelines established by the following federal court decisions provide school districts with some measure of
what is expected of them in determining the appropriate placement for children with disabilities. Please note
that each court has a separate jurisdiction and that the decision may not apply to all locations. However,
these cases have been cited by courts throughout the country in cases involving challenges to placement of
students in the least restrictive environment.
Greer vs. Rome City School District (11th Circuit Court, 1992)
In this case, the court decided in favor of parents who objected to the placement of their daughter in a selfcontained special education classroom. Specifically, the court said: "Before the school district may conclude
that a handicapped child should be educated outside of the regular classroom it must consider whether
supplemental aids and services would permit satisfactory education in the regular classroom."
The district had considered only three options for the child:
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The regular education classroom with no supplementary aids and services;
The regular classroom with some speech therapy only;
The self-contained special education classroom.
The district argued that the costs of providing services in the classroom would be too high. However, the
court said that the district cannot refuse to serve a child because of added cost.
On the other hand, the court also said that a district cannot be required to provide a child his/her own fulltime teacher. As in many decisions of this type, no clear determination is made about when costs move from
reasonable to excessive. The major message in this case is that all options must be considered before
removing a child from the regular classroom.
Sacramento City Unified School District vs. Holland (9th Circuit Court, 1994)
In this case, the circuit court upheld the decision of the lower court in finding for the Holland family. The
parents in this case challenged the district's decision to place their daughter half-time in a special education
classroom and half-time in a regular education classroom. The parents wanted their daughter in the regular
classroom full-time.
A number of issues were addressed in this decision. The court considered a 1989 case in Texas, (Daniel
R.R.), which found that regular education placement is appropriate if a disabled child can receive a
satisfactory education, even if it is not the best academic setting for the child. Non-academic benefits must
also be considered.
In upholding the lower court decision, the 9th Circuit Court established a four-part balancing test to
determine whether a school district is complying with IDEA.
The four factors were as follows:
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The educational benefits of placing the child in a full-time regular education program;
The non-academic benefits of such a placement;
The effect the child would have on the teacher and other students in the regular classroom;
The costs associated with this placement.
As a result of applying these factors, the court found in favor of including the child.
Oberti vs. Board of Education of the Borough of Clementon School District (3rd Circuit Court, 1993)
In finding for the parents in Oberti, the court ruled in favor of a placement that was more inclusive than that
provided by a self-contained placement. Specifically, the court ruled that three factors must be considered:
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The court should consider whether the district made reasonable efforts to accommodate the child in
regular education. The school must "consider the whole range of supplemental aids and services . .
."
The court should compare the educational benefits the child would receive in regular education
(with supplemental aids and services) contrasted with the benefits in a special education
classroom.
The court should consider the effect the inclusion of the child with disabilities might have on the
education of other children in the regular education classroom.
If, after considering these factors, the court determines that the child cannot be educated satisfactorily in a
regular classroom, the court must consider whether the schools have included the child in school programs
to the maximum extent appropriate.
Poolaw vs. Parker Unified School District (9 th Circuit Court, 1995)
In this case, the court ruled in favor of the district's offer of a residential placement contrary to the wishes of
the family that their child be educated in a regular education classroom. The court stated that the child's
previous and current district placements had adequately explored the effectiveness of regular education
placement with supplemental aids and services. In doing so, the district found that the benefits of regular
education placement were minimal and that the child's educational needs could be met appropriately only by
the residential placement offered by the district.
School District of Wisconsin Dells v. Z. S. (7 th Circuit Court, 2002)
The court held that the District’s decision to provide a home bound education program for a student with
autism did not violate IDEA. From kindergarten through fourth grade, Z. S. had a history of kicking and biting
people, tearing his clothes and breaking furniture. At age ten, he was placed in a residential facility where he
did well. The following school year, attempts were made to return him to the public school setting, but he
again was violent, disruptive, and truant. He was placed in a specialized school, but was removed after less
than a month. Finally, the District determined (after a month without providing services) that it would educate
the student at his home. Although the child’s guardian sued the district because she wanted him to attend
the public school, the court held that given the child’s history of unmanageable, violent behavior, the district
reasonably concluded that there was no basis for believing that he could function successfully in a regular
school environment.
There are other court decisions in favor of more restrictive placements, including a 1991 decision in the 8th
Circuit Court of Appeals that approved a centralized program for a wheelchair-bound student with spina
bifida. In this instance, the court decided that school authorities did not have to modify the neighborhood
school for wheelchairs when an accessible program was available elsewhere in the school district.
Conclusion
Courts will carefully examine the facts in individual cases to determine whether school districts have offered
an appropriate placement out of a continuum of placements available for every child with disabilities who is
enrolled in the district. Courts will examine IEP team processes to ensure that placements are based on the
individual needs of each child.
Research
There are no comparative data available on special education students' academic gains, graduation rates,
preparation for post-secondary schooling, work, or involvement in community living based on their
placement in inclusive vs. non-inclusive settings. Therefore, an accurate comparison between separate
programming and inclusive programming cannot be done.
The following is a brief review of a number of studies of various inclusive strategies. There are a number of
reviews and meta-analyses that consistently report little or no benefit for students when they are placed in
special education settings (Kavale, K.A., Glass, G.V., 1982; Madden and Slavin, 1983). However, in 50
studies comparing the academic performance of mainstreamed and segregated students with mild
handicapping conditions, the mean academic performance of the integrated group was in the 80th
percentile, while the segregated students score was in the 50th percentile (Weiner R., 1985).
Using this evidence, inclusion proponents claim that segregated programs are detrimental to students and
do not meet the original goals for special education. Recent meta-analyses confirm a small to moderate
beneficial effect of inclusion education on the academic and social outcome of special needs students.
(Carlberg, C. and Kavale, K. 1980; Baker, E.T., and Wang, M.C., and Walberg, H.J., 1994-95).
Another study assessing the effectiveness of inclusion was done at Johns Hopkins University. In a schoolwide restructuring program called Success For All, student achievement was measured. The program itself
is a comprehensive effort that involves family support teams, professional development for teachers,
reading, tutoring, special reading programs, eight-week reading assessments, and expanded opportunities
for pre-school and kindergarten children.
In assessing effectiveness, a control group was compared with the students in Success For All programs.
Comparative measures included:
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Woodcock Language Proficiency Battery (1984)
Durrell Analysis of Reading Difficulty (1980)
Student retention and attendance.
Comparisons were made at first, second, and third grades. Students identified with exceptional education
needs were included in all comparisons. While assessments showed improved reading performance for all
students, the most dramatic improvements occurred among the lowest achievers. In spite of the fact that
these inner city schools have normally high retention problems, only 4% of the fourth graders in the
experimental group had ever been held back one or more grades, while the five control schools had 31%
who had failed at least one year.
There was a similar finding in the comparison of attendance rates. The research also found the best results
occurred in schools with the highest level of funding. They concluded that when resources are available to
provide supplementary aids, all children do better.
The primary importance of research on Success For All is that it demonstrates that with early and continuing
intervention nearly all children can be successful in reading. Common practice in compensatory and special
education is to identify children who have already fallen behind and provide remediation services that last for
years (Allington and McGill-Frazen, 1990). Research on Success For All and other intensive early
intervention programs such as Reading Recovery (Pinnell, 1991) and Prevention of Learning Disabilities
(Silver and Hagen, 1989) suggests that there are effective alternatives to remedial approaches.
While researchers are cautious in their conclusions, there are some positive signs. In particular, students in
special education and regular education showed several positive changes, including:
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A reduced fear of human differences accompanied by increased comfort and awareness (Peck et
al., 1992);
Growth in social cognition (Murray-Seegert,1989);
Improvement in self-concept of non-disabled students (Peck et. al., 1992);
Development of personal principles and ability to assume an advocacy role toward their peers and
friends with disabilities;
Warm and caring friendships (Bogdan and Taylor, 1989).
The final issue shared by proponents of inclusion relates to cost-effectiveness. A 1989 study found that over
a fifteen year period, the employment rate for high school graduates with special needs who had been in
segregated programs was 53%. But for special needs graduates from integrated programs the employment
rate was 73%. Furthermore, the cost of educating students in segregated programs was double that for
educating them in integrated programs (Piuma, 1989).
A similar study by Affleck, Madge, Adams, and Lowenbraun (1988) demonstrated that the integrated
classroom for students with special needs was more cost-effective than the resource program, even though
achievement in reading, math and language remained basically the same in the two service delivery models.
Discussion
"Education, then, beyond all other devices of human origin, is the great equalizer of the conditions of men the balance-wheel of the social machinery." – Horace Mann
It is apparent throughout the literature that the amount of time that children are pulled out of regular
classrooms has become a concern. While in many cases pull-out is supported by the exceptional and
regular education teachers and parents, there is mixed evidence of improved academic performance. Most
groups and individuals believe that inclusion in the regular classroom is the appropriate starting point, and
that a continuum of placement options and services must be available. As noted in the legal section of this
paper, those decisions must be based on the needs of the child, her/his peers, and the system's ability to
meet those needs.
One of the greatest challenges contributing to this debate is the lack of similarity between the regular and
special education systems that exist in today's districts and schools (Wang, Reynolds and Walberg, 1988)
(Elliott, Barbara, and Riddle, Margaret, 1992). Successful inclusion practices depend on restructured
schools that allow for flexible learning environments, with flexible curricula and instruction. Under ideal
conditions, all students work toward the same overall educational outcomes. What differs is the level at
which these outcomes are achieved, the additional support that is needed by some students and the degree
of emphasis placed on various outcomes. A restructured system that merges special and regular education
must also employ practices that focus on high expectations for all and rejects the prescriptive teaching,
remedial approach that leads to lower achievement (Guess and Thompson, 1989, Heshusius, 1988).
We must also decide that diversity (ability, racial, etc.) is valuable. It is not just a reality to be tolerated,
accepted, and accommodated . . . it is a reality to be valued (York, et.al. 1993).
Recommendations
When considering a move from traditional/regular special educational programming to a more inclusive
approach, it is important that the entire school community be involved in a thoughtful, carefully researched
transition. Dramatic top-down directives will polarize parents and teachers and will create environments that
are hostile to any change.
As is true in other areas of school restructuring, change must be based on research and broadly shared
beliefs and philosophies. The following recommendations can help districts or buildings in designing a
positive transition to a more inclusive environment:
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A continuum of placements, supports and services should be made available for all students, but
always assume that every student's first placement is in regular education.
All placement decisions should be based on a well-developed IEP with an emphasis on the needs
of the child, her/his peers and the reasonable provision of services.
Top-down mandated full inclusion is inappropriate. Neither federal nor state law require full
inclusion.
Before any new programs are developed, the building staff must agree on a clearly articulated
philosophy of education (an education ethic). Teachers and support staff must be fully involved in
the decision-making, planning and evaluation processes for individual students and building-wide
programs.
Extensive staff development must be made available as a part of every teacher's and
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paraprofessional's workday. Areas of emphasis include:
 Emphasis on higher-order thinking skills
 Integrated curricula
 Interdisciplinary teaching
 Multicultural curricula
 Life-centered curricula.
Work toward unifying the special education and regular education systems. For instance, separate
evaluators and evaluation systems are counter productive. There should be one system.
Ensure that sufficient licensed practitioners are employed to address the social, emotional, and
cognitive needs of all students. In inclusive settings, reduced class sizes and/or increased numbers
of teachers in the classroom are necessary.
Appeal processes must be developed that allow teachers to challenge the implementation of IEP's
and placements that they determine to be inappropriate for a child.
Involve parents and students as partners in the decision-making process.
When developing programs, consider multiple teaching/learning approaches like team teaching, coteaching, peer partners, cooperative learning, heterogeneous grouping, study team planning,
parallel teaching, station teaching, etc.
Conclusion
It is critical that any district or building considering more inclusive practices take the time necessary to plan
effectively. Attention to special education students and staff alone is only half a strategy. Planning should
involve all stakeholders in researching, discussing and examining the entire educational program. Real
inclusion involves restructuring of a school's entire program and requires constant assessment of practices
and results. More comprehensive research must be done as inclusion becomes more widespread. Constant
reflection is necessary if we ever hope to be able to make clear determinations about which specific
strategies will help children to become happy, contributing citizens.
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Viability and Effectiveness." Exceptional Children (1988): 339-348.
Allington, Richard L., and Anne McGill-Franzen. "Comprehension and Coherence: Neglected Elements of
Literacy Instruction in Remedial and Resource Room Services." Journal of Reading, Writing, and Learning
Disabilities International (1990): 149-182.
Arnold, Jean B., and Dodge, Harold. "Room for All." The American School Board Journal (October, 1994):
10.
Baker, E.T., Wang, M.C., and Walberg, H.J. "The Effects of Inclusion on Learning." Educational Leadership
(1994-1995): 33-35.
Bogdan, R., and Taylor, S.J, "Relationships with Severely Disabled People: The Social Construction of
Humanness." Social Problems (1989): 36,2:135-148.
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Guess, D., and Thompson, B., "Preparation of Personnel to Educate Students with Severe and Multiple
Disabilities: A Time For Change?" Critical Issues in the Lives of People with Severe Disabilities, 1989.
Gordon, Stacey. “Making Sense of the Inclusion Debate Under IDEA.” 2006 B.Y.U. Educ. & L.J. 189 (2006).
Heshusius, Lous. "The Arts, Science, and the Study of Exceptionality." Exceptional Children (September
1988): 60-65.
Heshusius, Lous. " Reading Meaning Into Texts." Exceptional Children (March-April 1992): 472-475.
Howard, Patrick. “The Least Restrictive Environment: How to Tell?” 33 J.L.& Educ. 167 (April, 2004).
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Madden, N.A., and Slavin, R.E. "Mainstreaming Students with Mild Handicaps: Academic and Social
Outcomes." Review of Educational Research (1983). 519-569.
McLaughlin, Margaret. "What Makes Inclusion Work?" Doubts and Certainties, (January/February, 1995).
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Osborne, Allan G. “Is the Era of Judicially-Ordered Inclusion Over?” 114 Ed. Law Rep. 1011 (February,
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Peck, C .A., Carlson, P., and Helmstetter, E. "Parent and Teacher Perceptions of Outcomes for Typically
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Piuma, Mary F. Benefits and Costs of Integrating Students With Severe Disabilities Into Regular Public
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Rogers, Joy. The Inclusion Revolution. Bloomington: Phi Delta Kappa, 1993.
Silver, Larry B. The Assessment of Learning Disabilities: Preschool Through Adulthood., Boston: Little
Brown, 1989.
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Wang, M.C., Reynolds, M.C., and Walberg H.J. "Serving Students at the Margins," Educational Leadership
(1988): 12-17.
Webb, N. "With New Court Decisions Backing Them, Advocates See Inclusion as a Question of Values."
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Weiner, R. Impact on the Schools. Capitol Publications. (1985).
Weisman, M.L. "When Parents Are Not in the Interest of the Child." The Atlantic Monthly (July 1994): 43-44,
46-47, 50-54, 56-60, 62-63.
Winners All: A Call for Inclusive Schools. Alexanderia, VA: National Association of State Boards of
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This paper was written in 2001 by Katie Schultz Stout, WEAC's Director of Instruction and Professional
Development, and updated in 2007 by Joanne Huston, Teaching and Learning Consultant/ Legal Counsel
Posted March 15, 2007