THE INCLUSION DEBATE 1

The Inclusion Debate:

Under what circumstances, and in what manner should selected children be provided inclusive or separate treatment in schools?

Introduction The debate over inclusion of special education students in regular education classes has been likened to that of the segregation of African Americans and has evolved into a civil rights movement with philosophic and moral foundations. The debate is dynamic and complex because stakeholders, ranging from full-inclusionists to those proposing segregated services, have solid reasonsboth empirical and ethicalfor their positions. The guiding question when considering the needs of students with special needs is: under what circumstances and in what manner should selected children be provided inclusive or separate treatment in schools? This document is intended for teachers, school board members, and administrators; it outlines the major views and evidence of stakeholders in the inclusion debate and offers a model for supporting students with special needs. School districts in the United States have increasingly attempted to provide a free appropriate public education for children with disabilities since the enactment of Public Law 94-142, the Education of All Handicapped Children Act of 1975 (EHA). An education is said to be appropriate if it is designed specifically to meet the unique needs of an individual child under an individualized education plan (IEP). Such a plan is also to be carried out in an appropriate educational setting; the setting is at the heart of the inclusion debate. When the EHA was reinstalled under the Individuals with Disabilities Education Act (IDEA) in 1990 and in subsequent years, it emphasized that students with disabilities be educated in the least restrictive environment (LRE). This means that a student should be educated in a setting that differs as little

THE INCLUSION DEBATE 2 as possible from the regular classroom while still being appropriate for the particular child. In order to create an environment that is inclusive and meets the needs of students with special needs, classroom teachers and peers must not only accommodate, but they may also need to change and adapt to provide a more suitable setting. The concept of modifying the educational environment to include students with special needs has come to be known as inclusion, but the term inclusion has different interpretations among stakeholders. To many in the field of education, inclusion means full inclusion100 percent of students being educated within the regular classroom 100 percent of the time. Others hold a more relaxed meaning for inclusion such as a purposeful effort to more fully include children with disabilities into all aspects of school. Still, others maintain that a continuum of services, that might include segregated instruction as an option, is necessary to provide an appropriate education for some students. The term inclusion, for the most part, has replaced the term mainstreaming in the literature. Mainstreaming is viewed more as a passive approach that implies the exceptional child will adjust to the regular classroom instead of the teacher and peers adapting to include the exceptional child. In his book, The History of Inclusion in the United States, Robert Osgood explains seven core issues in the inclusion debate: efficacy, efficiency and economy, territory, community, legality, power and identity, and axiology (2005). Efficacy raises the question of whether segregated or integrated settings are more effective in helping all students succeed academically, socially, and emotionally. In dealing with efficiency and economy, one must understand the practical implications of full-inclusion such as the impact on classroom management and limited financial resources. Territory refers to where responsibility lies for making decisions about programs and instruction, delivering instruction, and evaluating students and programs.

THE INCLUSION DEBATE 3 Community examines the importance of a sense of community in the classroom and school and between disabled and non-disabled peers as well as among students with disabilities. The legality surrounding special education has favored inclusion and has limited segregated settings. In addition, laws have placed demands on school districts that can be difficult to meet for a number of reasons. Power and Identity recognize that the debate over inclusion represents broader issues in society such as the struggle for persons with disabilities to be seen as able or the continued marginalization of persons with disabilities. Axiology acknowledges the moral and ethical aspects of the inclusion debate in conjunction with the legal and practical aspects. Overview of viewpoints At one extreme is the idea of full inclusion where students who are exceptional based on physical or mental characteristics are not isolated into separate schools, classes, or pull-out sessions; they remain in the general education classroom 100 percent of the time. People who hold a full-inclusion viewpoint base it on the democratic principles of equal opportunity and justice. Full-inclusion allows students with disabilities to participate fully in the school community and prepares all children for a more inclusive society. For the most part, the opposite end of the spectrumpeople who desire completely separate programs in completely different schools for students with special needsdoes not exist, with the exception of the deaf community in some cases. Opponents of full inclusion strive for a continuum of services for students with special needs; they insist that special programs help special students. They emphasize that full inclusion may not be the best choice for all students and may be detrimental to students with disabilities as well as students in the regular classroom. While they agree that full inclusion should be considered for many students with disabilities, they dont agree that it is ideal for all children.

THE INCLUSION DEBATE 4 Viewpoint #1: Full Inclusion A foundational principle guiding those who support full inclusion is that all students have a right to be in the general education classroom. Just as separate is not equal under the Brown v. Board of Education decision (1954), neither are segregated classes designed for students with special needs. Even though the Brown case was referring to the segregation of racially diverse children, the court issued this statement, Separate educational facilities are inherently unequal, because evidence from social scientists has shown that segregation causes a sense of inferiority and negatively affects the motivation of the child to learn. In addition, there is often an overrepresentation of culturally and linguistically diverse students in special education, which can lead to racial segregation when students are not fully included in the regular classroom (Oswald, Coutinho, Best, & Singh, 1999). Based on principles such as fairness and honoring diversity, supporters of this viewpoint believe it is wrong to separate those who differ based on physical, mental, or emotional problems. Causes of disabilities such as genetics, birth defects, medical mishaps, disease, parental negligence, accidents, and lack of health care are out of a students control so it is not fair to deny access to an appropriate education in the general classroom. Nelson, Palonsky, and McCarthy explain how average is just a guide, not a measure to rank human qualities: Exceptional children are exceptional when compared with certain measures of average, but every child differs from average in some respect (2010, p. 432). From a students point of view, segregation is stigmatizing, degrading, and emotionally devastating (Sullivan et al., 2009). Even students with mild disabilities are pulled out for remedial programs two-three times per day resulting in a fragmented day. The message that is sometimes absorbed by these students is that something is wrong with them and they need to be

THE INCLUSION DEBATE 5 separated in order to fix it. On the other hand, inclusion creates an atmosphere of acceptance and opportunities for socializing between disabled and non-disabled students; regular education students will benefit from more diverse social interactions and will develop a sincere appreciation for others. Parents believe that through integration, students can learn lessons about the rights of all people that will lead to a more inclusive society as a whole (Osgood, 187). Both parents and community members often maintain that social benefits of full-inclusion for both students with disabilities and normal students are just as important as academic concerns. By denying exceptional children full inclusion in schools, we are essentially limiting their full participation and contributions to society. Furthermore, there is a substantial legal basis for more inclusive schools and full inclusion is the next step. The EHA of 1975 contained an important least restrictive environment clause that has propelled the inclusion movement. Under IDEA, the LRE section states that schools must ensure that: to the maximum extent appropriate, children with disabilities, including children in private or public institutions or other care facilities, are educated with children who are non-disabled; and special classes, separate schooling or other removal of children with disabilities from the regular educational environment occurs only if the nature or severity of the disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily. ( 300.114(a)(2)) Although IDEA does not require every student to be placed in a regular classroom and calls for a continuum of alternative placements, the regular education classroom is the first placement choice the IEP team must consider.

THE INCLUSION DEBATE 6 Court decisions have also recognized that students be educated in the LRE to the maximum extent appropriate. In N.R. v. Kingwood Township Board of Education (2000), N.R., a child on an IEP, was placed in a hybrid preschool classroom with about half disabled children and half non-disabled children and the court decided that the school must first attempt to accommodate the child in a regular classroom with supplementary aids and services. In a prior case, Mills v. Board of Education of the District of Columbia (1972), the court decided that lack of funds was not an excuse for not providing an appropriate inclusive education for students with special needs. In Oberti v. Board of Education of the Borough of Clementon School District (1993), parents of an eight year old boy with Down Syndrome sued the school district for not complying with the mainstreaming requirement in the IDEA; the court found that the school district did in fact violate the IDEAs condition that a child be educated in the regular classroom to the maximum extent appropriate because they did not first attempt to provide supplementary aids and services before moving the child to a special education program in another school district. Another reason for full-inclusion is that segregated settings or partially separate settings have not necessarily been shown to be more effective, academically, than full-time regular classroom placements. The literature varies on academic results based on placement structure for special education students, and more solid research is needed to determine if where special education students are educated is a significant factor for academic success (Zigmond, 2003). Since segregated service delivery models have not been successful and are used in many schools, taxpayers wonder why schools continue to fund such programs when it takes nearly twice as much money to educate a student with a disability than it does to educate a regular education student (Parrish, 2006). When students are educated outside of the regular classroom, they

THE INCLUSION DEBATE 7 require a separate space, separate materials, a separate teacher and an administrator to manage the program, all leading to increase costs. The effectiveness and efficiency strands of research are very important for administrators and teachers as they are the ones to make decisions about how special education programs function. Proponents of full-inclusion also claim there are more opportunities for special educators and regular teachers to pool knowledge when exceptional children stay in the general classroom (Osgood, 2005). Co-teaching, between the regular teacher and a special education teacher, is one inclusive practice that benefits all children in the classroom and acts as a way to merge special and general education (Byrnes, 2011). Brownell and others suggest that dual certificationboth general and special education endorsementsfor new classroom teachers is necessary to ensure they are prepared to teach students with disabilities in the regular classroom (2010). The Arc and The National Council on Disability (NCD) are among the organizations that support full-inclusion as a goal (Osgood, 185). Although NCD acknowledges positive aspects of a continuum of services, they assert that reliance on it has slowed down the movement toward more genuine integration. As you will see in the next viewpoint, there are many obstacles to fullinclusion and some stakeholders see it more of an ideal than a reality. Viewpoint #2: Careful Inclusion Those in favor of careful inclusion, or what is called a continuum of services, do agree that we should include students with disabilities as much as possible in regular classrooms, but they see many problems with applying full-inclusion as a mandate for all students (Osgood, 2005). They explain that the nature of special education is individualized instruction and we cannot assume that full inclusion is the best way to meet the needs of all students. An individualized education plan is meant for a team of professionals and parents to decide what is

THE INCLUSION DEBATE 8 best for each child; insisting that each child must remain in the general education classroom, even when it is not beneficial, is counter to the purpose of an IEP. Smelter, Rasch, and Yudewitz, in their article, Thinking of Inclusion for All Special Needs Students? Better Think Again, state their opinion bluntly, To consider oneself an inclusionist is to place a philosophy before the needs of children (1994, p. 38). Even though the language of the IDEA is meant to be as inclusive as possible, it is not meant to be inflexible in regards to student placement. The LRE section of the IDEA explains that when the nature or severity of the disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily, then special classes are appropriate ( 300.114(a)(2)). In Sacramento City Unified School District v. Rachel H. (1994), the court decided that Rachel should be placed full-time in a regular classroom with supplementary aids and services. However, the court considered the following factors in determining her placement: (1) the educational benefits of the regular classroom (supplemented with appropriate aids and services), as compared with the educational benefits of a special education classroom; (2) the non-academic benefits of interaction with children who were not disabled; (3) the effect of the students presence on the teacher and other children in the regular classroom; and (4) the cost of mainstreaming in a regular classroom. The regular classroom could be the least restrictive educational environment for some individuals; however, by definition, the mainstream is not necessarily the least restrictive educational environment as intended in the law (Grosse, 1991, p. 43). Educators should realize that the mainstream is not always the place for the child to reach their optimum potential. When an IEP team determines that a child would best be served outside of the general education classroom for some or all of the day, the burden of proof in challenging this decision is

THE INCLUSION DEBATE 9 on parents. The courts respect educators discretion in applying the mainstreaming clause of IDEA as in Schaffer v. Weast (2005). Special education teachers have been trained to develop lesson plans and interventions for individual students and they are in a position to lead a team to make judgments about how to best educate a student with special needs. Additionally, in Hartmann v. Loudon County School Board (1998), the courts upheld a school districts decision to educate an autistic child outside of the regular classroom after training staff and providing supplementary services for the student were shown to be ineffective in the regular classroom. The three-part test in Hartmann revealed that full inclusion is not required when: a student with a disability would not receive educational benefit, any marginal benefit from mainstreaming is significantly outweighed by benefits in a separate setting, or the student is a disruptive force in the classroom. Beyond the ethical and legal reasons for a continuum of services offered by special education teachers are the practical implications. There are thirteen categories of disability with a wide range of severity levels; classroom teachers are not prepared to accept the full responsibility of educating all of theses students. Even if regular classroom teachers were trained to include all students with disabilities, is it fair to increase the workload of already overworked teachers? When the regular classroom teacher diverts considerable amounts of time and energy to fully include some students, the education of regular education students is likely to be limited in some ways (Nelson et al., 2010). Also, some regular education students are not able to adapt to frequent disruptions from the behavioral problems of students with special needs. When full inclusion is forced on schools and teachers who are not ready, it becomes a lose-lose-lose situation; the students with special needs do not get specialized instruction, the education of regular education students is disjointed, and the teacher is exhausted and discouraged.

THE INCLUSION DEBATE 10 Furthermore, schools do not have an unlimited amount of staff and resources to offer students with special needs. Although lack of funds is not a valid reason for not including a student to the maximum extent possible, in Hendrick Hudson Central School District v. Rowley (1982), it was decided that schools do not have to provide the best education possible to maximize each childs potential as long as the student is benefiting from their placement and the procedural requirements of the IDEA are followed. At some point, school districts have to consider how to balance funds to meet the needs of all their students; each district has a restricted budget and must run efficiently while simultaneously complying with laws. Recommendations/ Conclusion After examining both viewpoints in the inclusion debate, we are still left with the question of how to best meet the needs of students with disabilities. Both sides agree that, The regular classroom requires fundamental reorganization for inclusion, let alone full inclusion, to work. How far are schools, teachers, parents, or students willing to go? (Osgood, 2005, p.195). After over three decades of research focused on the question of: What is the best setting or place to educate students with special needs, many researchers and educators are asking different questions such as: How do we restructure our schools to better meet the needs of students with special needs? How can we make our schools more inclusive? The setting is not the most important aspect of teaching children with special needs so much as how the learner responds to variables in the setting. From 1976 to 2004, the number of special education students in public and private schools has increased from about 3,692,000 students, representing 7.5 percent of the total K-12 population, to about 6,634,000, representing 12.2 percent of the total K-12 enrollment (Parrish, 2006). There is concern that there has been an over-identification of students with learning

THE INCLUSION DEBATE 11 disabilities in part from schools failure to employ effective, evidence-based practices. The use of such practices minimizes the misidentification of students as learning disabled by ruling out the possibility of inadequate instruction (Brownell et al., 2011, p. 174). Response to Intervention (RTI) was approved under No Child Left Behind (NCLB) and the IDEA as a preferred method for identifying students qualifying for special education services. The National Center on Response to Intervention (NCRTI) offers the following definition of RTI: Response to intervention integrates assessment and intervention within a multi-level prevention system to maximize student achievement and to reduce behavioral problems. With RTI, schools use data to identify students at risk for poor learning outcomes, monitor student progress, provide evidence-based interventions and adjust the intensity and nature of those interventions depending on a students responsiveness, and identify students with learning disabilities or other disabilities. (2010, p. 2) At the heart of RTI is the primary level of preventionhigh quality core instruction that meets the needs of most students. The secondary level of prevention involves evidence-based interventions of moderate intensity that address the learning or behavioral challenges of most atrisk students. At the tertiary level of prevention, individualized interventions of increased intensity are implemented for students who show minimal response to secondary prevention. Generally, special education teachers are involved at the secondary and tertiary levels and students who need the top level of prevention are often identified as having a disability (NCRTI, 2010). Although RTI does not fully resolve the inclusion debate, it is a framework that can be used to effectively meet the LRE requirements of the IDEA and prevent many students from being removed from the general education classroom. In applying RTI, teachers, special

THE INCLUSION DEBATE 12 education teachers, specialists, administrators, and parents can all work together to find what is best for the individual child. Some have argued that until there is clear evidence that RTI methods produce improvements, RTI should not be used at a large-scale level. However, the problem with waiting to implement RTI on a large scale is that the only way to determine whether it will achieve its promise is to implement it at the state or national level (BrownChidsey & Steege, 2005 as cited in Byrnes, 2011, p. 150). Frattura and Capper suggest that research on inclusive education in the past decade has focused on the classroom site, collaborative teaching, the role of paraprofessionals, statewide assessments, integrating curriculum, or on conceptual and ideological concerns in the inclusion debate (2006). They suggest that research should instead emphasize the organizational, structural, and cultural conditions necessary for inclusion. Their proposed model, Integrated Comprehensive Services (ICS), similar to RTI in that the main focus is on prevention, offers reform at the school and district level to ensure the success of all students, especially students with disabilities. Four cornerstones of ICS include: core principles, location of services, curriculum and instruction, and funding and policy. From these four cornerstones, ICS has landed on five nonnegotiables for service delivery: least restrictive, least intrusive, least disruptive, and least enabling, which they believe are ultimately the least expensive. In answer to the question on how to make our schools more inclusive, expanding teacher training and building teacher capacity to differentiate instruction to meet the needs of a wide range of learners is at the top of the list. Preparing and guiding teachers to teach more inclusively is beneficial, not only for students with disabilities, but for English language learners, gifted students, and struggling readers (Fraturra & Capper, 2006). Brownell offers suggestions on how to use an RTI framework to rethink teacher preparation programs, both for the general and

THE INCLUSION DEBATE 13 special education teacher; general education teacher will need more preparation to implement tiers 1 and 2 interventions of RTI and special education teachers will need expertise in content areas in order to deliver tier 3 interventions (2010). For some school districts, part of the solution to meeting the needs of exceptional children may be centralizing special education services in certain schools (Osborne & Dimmatia, 1994). The courts upheld the practice of centralized special education programs in Barnett v. Fairfax County School Board (1991) when they determined a high school student was maintaining satisfactory grades, participating in extracurricular activities, and mainstreamed satisfactorily as part of a centralized program in a school outside his neighborhood. The court recognized that school districts have limited resources and centralized programs are one way to better serve all students. However, the IDEA states that in determining the educational placement of a child with a disability each public agency must ensure that it is as close as possible to the childs home ( 300.116 (b)(3)). For this reason, full inclusionists would probably still have some reservations about the centralizing of special education services because it is in some ways a form of segregation where students are not able to attend their neighborhood school. Osgood describes one possibility for resolving the inclusion debate: Any child who wishes to be educated in a regular class has the right to be there, and the school and district must engage in aggressive steps to make that a reality (2005, p. 199). For students who opt out of attending the regular class, alternatives can be developed. He goes on to explain that inclusion of all students then becomes a priority for school districts and the inclusion debate becomes a matter of choice. For nearly all stakeholders involved in the inclusion debate, the goal of special education is for students with disabilities to become productive citizens. Full inclusion is the preferred way to reach that goal, but stakeholders from both points of view acknowledge that for

THE INCLUSION DEBATE 14 full inclusion to work, the restructuring of schools is necessary. Even then, full inclusion has limitations, but should still be our aspiration.

References Barnett v. Fairfax County School Board, 927 F.2d 146 (1991). Brown v. Board of Education of Topeka, Kansas, 347 U.S. 483 (1954). Brown-Chidsey, R., & Steege, M.W. (2005). What is response to intervention (RTI)? In Byrnes, M. (Ed.). (2011). Taking sides: Clashing views in special education (5th ed.). NY:

THE INCLUSION DEBATE 15 McGraw-Hill. (Reprinted from Response to intervention: Principles and strategies for effective practice, NY: Guilford Press.) Brownell, M.T., Sindelar, P.T., Kiely, M.T., & Danielson, L.C. (2010). Special education teacher quality and preparation: Exposing foundations, constructing a new model. Exceptional Children, 76(3), 357-378. Retrieved April 29, 2011, from Proquest database. Byrnes, M. (2011). Taking sides: Clashing views in special education (5th ed.). New York: McGraw-Hill. Frattura, E., & Capper, C. (2006). Segregated programs verses integrated comprehensive service delivery for all learners: Assessing the differences. Remedial and Special Education, 27(6), 355-364. Retrieved April 17, 2011, from Proquest database. Grosse, S. (1991). Is the mainstream always a better place to be? Palaestra, 7(2), 40-46. Retrieved April 10, 2011, from Academic OneFile database. Hartman v. Loudon County School Board, 118 F.3d. 996 (4th Cir. 1997), cert. denied, 522 U.S. 1048 (1998). Hendrick Hudson Central School District v. Rowley, 458 U.S. 176, 102 S.Ct. 3034 (1982). Individuals with Disabilities Act, 34 C.F.R. 300.114-116 (2004). Mills v. Board of Education of the District of Columbia, 348 F.Supp. 886 (1972). National Center on Response to Intervention. (2010). Essential components of RTI A closer look at response to intervention. Washington, DC: U.S. Department of Education, Office of Special Education Programs. Retrieved from website, http://www.cldinternational.org/Articles/rtiessentialcomponents.pdf Nelson, J., Palonsky, S., & McCarthy, M. (2010). Critical issues in education: Dialogues and dialectics. New York: McGraw-Hill.

THE INCLUSION DEBATE 16 N.R. v. Kingwood Township Board of Education, 205 F.3d 572 (2000). Oberti v. Board of Education of the Borough of Clementon School District, 995 F.2d 1204 (1993). Osborne, A., & Dimmatia, P. (1994). The IDEAs least restrictive environment mandate: legal implications. Exceptional Children, 61(1), p. 6-14. Retrieved April 22, 2011, from Proquest database. Osgood, R. (2005). The history of inclusion in the United States. Washington, D.C.: Gallaudet University Press. Oswald, D., Coutinho, M., Best, A., & Singh, N. (1999). Ethnic representation in special education: The influence of school-related economic and demographic variables. The Journal of Special Education, 32(1), 189-206. Retrieved April 28, 2011, from Proquest database. Presenter, Parrish, T.B. (2006, March). National and state overview of special education funding. Power point presented at the meeting of Kansas Association of Special Education Administrators. Retrieved from the Center for Special Education Finance (CSEF) website: http://csef.air.org/presentations/KS%20SE%20presentation%203-1-06.pdf Sacramento City Unified School District v. Rachel H., 14 F.3d 1398 (1994). Schaffer v. Weast, 546 U.S. 49, 126 S.Ct. 528 (2005). Smelter, R., Rasch, B., & Yudewitz, G. (1994). Thinking of inclusion for all special needs students? Better think again. Phi Delta Kappan, 76(1), 35-38. Retrieved April 27, 2011, from Proquest database. Sullivan, A., AVant, E., Baker, J., Chandler, D., Graves, S., McKinney, E., et al. (2009). Confronting inequality in special education, part 1: Promising practices in addressing

THE INCLUSION DEBATE 17 disproportionality. Comminiqu, 381(1), 1, 14-15. Retrieved April 27, 2011, from Proquest database. Zigmond, N. (2003). Where should students with disabilities receive special education services? Is one place better than another? The Journal of Special Education, 37(3), 193-199. Retrieved April 21, 2011, from Proquest database.