Special education's hottest topic over the past decade has been where, not how, special education students should be taught. Inclusion, a colloquial term applied to educating students with and without disabilities together within regular classes in neighborhood schools, has become the topical flash point. As a political concept, inclusion captures the moral high ground by signifying something more desirable than the symbolically bereft notion of "exclusion." As a legal concept, however, inclusion falls short of the Individuals with Disabilities Education Act (IDEA). As an educational concept, inclusion fails to describe concretely the instructional supports and strategies that facilitate the relationship between a student's specific learning needs and the classroom elements required to address those needs.
Multiple Interpretations of Inclusion
The notion of inclusion poses a challenge for those wishing to study it more systematically because practices described as inclusive differ markedly from setting to setting. Some models propose the inclusion of literally all students with disabilities and define this as full inclusion. Others define full inclusion as regular class placement for all students with disabilities, but on a part-time basis for some; still others propose the inclusion of students for whom it is appropriate or even suggest that separate, special schools are part of their inclusion plan (Sack, 1997). Ed Martin (1995), who served as the director of the Bureau for the Education of the Handicapped when Congress passed the original Education for All Handicapped Children Act, suggests that "as a matter of public policy, a federal or state government, even a local school system, cannot responsibly adopt 'inclusion' with-out defining its proposed program" (p. 193).
MacMillan, Gresham, and Forness (1996) aptly point out the problems with the term's multiple meanings: If it means that regular class placement should be available for some children with disabilities, then it has been available for years, and there is no need for a specific term "full inclusion." If it refers to the placement of allchildren with disabilities in age-appropriate regular classes all day in their neighborhood schools, then its adoption requires the abolition of the continuum of placements provided for in the Individuals with Disabilities Education Act. (p. 147, italics in original)
To get to the root of the issue, we explored the origins and multiple interpretations of inclusion and the least restrictive environment (LRE) in special education. We sought historical evidence from parents, case law, and educational practices to determine the original appeal of alternative placements. We also examined current evidence from parents, courts, and classrooms to determine whether support for general inclusion, rather than the individualized determinations of LRE, represents changes in cultural values, more precise implementations of law, or greater readiness of general education to meet the needs of exceptional learners.
Parents: Meaningful Opportunities to Learn
Thirty years ago, parents were united in advocating for children with disabilities to have educational access to a variety of state-provided public education programs. Nationwide, from 1972 through 1974, 47 right-to-education cases, brought mostly on behalf of students with mental retardation, were heard in 28 states. From today's perspective, these earlier cases seem to represent a relatively homogenous group, unlike the widely divergent group affected by the full inclusion movement. Now that total exclusion from services is not the threat, some theorists expect parents to advocate for more specialized services in regular classes. We found that not all parents of children with disabilities view the regular classrooms in their neighborhoods as capable of providing meaningful opportunities to learn, despite the best intentions of supplementary aids and services. In fall 1996, a group of parents, dissatisfied with public services for their children, founded the Virginia Institute for Autism. One parent observed that the payoff for her son's "segregation" is in his rate of recovery. She remarked that so much in the treatment of autism is counterintuitive that her son's general education teachers often inadvertently hindered rather than helped him learn to cope with his classroom environment.
Kotler (1994), an attorney and father of a child with autism, suggests that several placement practices collide with the issues posed by autism, which is misunderstood, underdiagnosed, and variable in its manifestations. Can a program be appropriate if teachers do not use effective methods? When can districts dismiss methodological approaches based on solid research by simply stating that they do not offer these options? How does classroom ecology affect the faithful application of a particular approach? Although we are aware of the controversy surrounding various approaches to the treatment of autism, this controversy does not negate these or other parents' perspectives on LRE (see Gresham & MacMillan, 1997a; 1997b; and Smith & Lovaas, 1997).
Advocacy organizations whose members include parents, professionals, and persons with various disabilities have issued position papers addressing the concept of full inclusion. Advocates for the Association for Persons with Severe Handicaps hail inclusive education as "a new way of thinking that embraces a sociology of acceptance of allchildren into the school community as active, fully participating members" (TASH, 1993). Other groups representing diverse learners question regular education's capacity to differentiate instructional and behavioral approaches for all students. Their statements call for appropriate education, not with visionary zeal, but with a view toward supports that are feasible to implement in classrooms across a continuum of placements.
Both proponents and opponents of full inclusion can produce impassioned testimony from parents who support their views. These conflicting profiles of what constitutes a meaningful education for children with diverse learning needs influenced the preservation of the continuum and the individualized principles of LRE in the 1997 amendments to the IDEA. The statute is not insensitive to parental perspectives and now calls for the participation of parents in any decisions related to the instructional placement of their child.
Commenting on the current status of parental advocacy regarding inclusion, Borthwick-Duffy, Palmer, and Lane (1996) observe that parents who are satisfied with the traditional provision of special education for their children have had little cause to express their views. As a result, those parents who support the preservation of the continuum of placements have received minimal, if any, media exposure. As Borthwick-Duffy, Palmer, and Lane remark, "Contented citizens make tedious human interest stories" (p. 312).
Law: Provide Educational Benefits
In law the argument for the least restrictive environment has never been an immutable rule of placement, but a rebuttable presumption favoring inclusion of children in regular classes but allowing separation in certain instances (Yell, 1998). The term LRE is derived from the concept of the least restrictive alternative, which has its legal basis in the U.S. Constitution and serves to balance individual and state interests. As long ago as 1819, Chief Justice Marshall of the United States Supreme Court . . . indicated that regulation affecting citizens of a state should be both "appropriate" and "plainly adapted" to the end sought to be achieved. (Burgdorf, 1980, p. 278)
Legal scholar Perry Zirkel (1996) reports that the courts have given an equivocating answer to whether placement of a child with a disability in a regular classroom is, indeed, the least restrictive environment. The ambiguous answer, in each case, is this: It depends. Says Zirkel, "Courts have not used a per se, or automatic, 'yes' answer any more than they have used a per se 'no' answer" (p. 5). Decisions reflect a common core of criteria that includes a comparison of educational benefits with an overall preference for placement in the regular classroom.
As early as 1980, Burgdorf remarked, Ideally, the law ought to set up a framework and some broad guidelines, within which public educators can exercise their professional discretion in selecting an educational program and placement designed to meet the needs of each individual handicapped student. (p. 273) In recent years, several significant cases have devised tests, or analytic frameworks, by which to evaluate whether a student is achieving satisfactorily in the regular classroom. The major frameworks include the Roncker standard, the two-pronged test from Daniel R.R., and the Holland test (see Crockett & Kauffman, in press; Yell, 1998, for discussion). Currently, no national framework is used in placement decisions, and to date the Supreme Court has declined to hear any LRE cases.
In an effort to synthesize the various frameworks as an aid to placement decisionmakers, Yell (1995) suggests the following guidelines: Determination of the LRE is based on the individual needs of the student; schools must make good-faith efforts to maintain students in integrated settings, but districts are not required to actually place a student in a regular classroom, or set him or her up for failure there, before recommending a separate placement; each school district must make available a complete continuum of alternative placements to meet the needs of each special education student; when students are placed in separate programs, they must be integrated in regular settings to the maximum extent appropriate to their needs; and the needs of nondisabled peers may be considered in determining placement of the LRE. All the tests consider the potential disruptive effect of the student with disabilities on the instructional environment.
Congress, in developing the original 1975 Act, viewed the regular classroom as the optimal setting but acknowledged that schools must offer instruction in multiple environments to appropriately meet individual needs. In 1997, when amending the statute, Congress similarly recognized that schools must base decisions for students with disabilities on individual need but justify their decision in the individual education program (IEP) if they recommend an alternative placement to regular classes. Ed Martin, who helped frame the original legislation, finds a change neither in its philosophy nor in its goals necessary. The key is in demonstrating what "appropriate" means. Where we've gone wrong in special education is that we haven't followed how kids have done. We have not interpreted "appropriate" as empirically derived by student outcomes. We have used argument instead of data in making placement decisions. (Martin, personal communication to J. B. Crockett, April 1996) By proceeding without data, the field has been susceptible to what Martin calls "the myth of mildness"—that these students are not so tough to teach or so different in their educational needs. "Without data," he says, "all we have are assumptions."
Educators: Ensure Productive Learning
Internationally, the public calls for competitive standards, accountability, equity, and excellence for all students at the same time it voices concerns about opportunities to learn for those least equipped to compete. We found that most educators, while embracing greater participation of students with disabilities in the educational mainstream, fear a loss of equity for students with disabilities unless they are provided with appropriate curriculum and instruction, supportive peer and teacher interactions, and suitable organization and management of their educational environments. For example, Cook, Gerber, and Semmel (1997) observe that recent recommendations for academic excellence have overpowered the call for equity that gave rise to federal programs in the 1960s. With regard to the emphasis on both accountability and classroom inclusion for students with disabilities, Cook and colleagues ask a salient question: "Is the attractive ideal of academic excellence for all more than idealistic whimsy or idle banter to enhance the political acceptability of either reform?" (p. 136).
The delivery of special education services has been fraught with controversy about which students to serve, which curriculum to use, and where to provide instruction (Kauffman & Trent, 1991). Consequently, many educators in elementary and secondary schools feel unprepared to face predicaments with regard to special education initiatives. Administrators' skills, knowledge, and understanding are challenged as they attempt to accommodate increasing numbers of students with disabilities into general education classrooms. They must cope with their own and their faculty's lack of preparation for educating students with special needs (Scruggs & Mastropieri, 1996). Inclusive but often inadequate instructional approaches for students with disabilities threaten to —alize special education from the center of school reform, which emphasizes, not downplays, the importance of curriculum, academic standards, and student and teacher accountability. This specter becomes more real in the face of systematic data confirming that reform efforts pay little substantive attention to special education or to students with disabilities (Meyers, Truscott, Borelli, & Gelzheiser, 1997).
The term inclusion has become almost synonymous in the public mind with special education, threatening to place an overemphasis on the schools and classrooms that students should attend—rather than on the instruction they should receive. Recent research calls for a return to the roots of special education to clarify what specialized instruction entails and for whom it is and was intended in the first place. Zigmond (1997) reminds us that special education is essentially instruction based on individual need. Educators must plan this instruction with care and coordination and deliver it with intensity, urgency, and a relentless drive toward clear instructional goals. Lieberman (as cited in Crockett & Kauffman, in press) emphasizes that special education was never intended for general education's failures. Special education is for students with disabilities whose futures are in danger of being handicapped by these disabilities unless they receive specific educational assistance.
From Roots to Results
Such targeted instruction might mean different things for different students. What is appropriate for whom, and under what circumstances is it appropriate? To provide effective special education, reformers need a deeper understanding about learning, exceptionality, and equity for students whose educational needs often require an extraordinary response (cf. Kauffman, 1997). To this end, Doug Fuchs (cited in Crockett & Kauffman, in press) suggested three principles for educational leaders, emphasizing the direct relationship between effective special education and effective general education: high expectations for all students, valid accountability systems, and the implementation of best instructional practices.
Viewed from this perspective, educational leadership on behalf of students with disabilities extends well beyond facilitating inclusive schools. It requires a rich appreciation of multiple perspectives and a greater understanding of specialized instruction. Skilled practitioners at work in an array of flexible instructional settings, including separate classes and schools, can ensure educational benefits to students with disabilities.
