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Essay On Inclusion

Inclusion in the American Public Schools:
The History, the Law, the Controversy

Ima Sample
7U: 100 Mainstreaming the Exceptional Learner
March 2, 200x

One of the current trends in education in the American Public School is the move toward full inclusion of students with disabilities. There has been a rapid rise in the number of students with disabilities who are spending their school day in a general education classroom under the guise of full inclusion. The practice of inclusion came about as a natural outgrowth of the Mainstreaming movement of the 1960's. Inclusion is purported to be based on the rights of the students and the social benefits that they receive from being in a general education classroom. There are many who see this as a solution to the problem of how to best educate children with disabilities. On the other hand, there are those who believe that this practice is based solely on the feelings of what the inclusionists see as socially correct, and not on any real benefit to the students involved. The question, which is now an often debated one, is whether or not this practice of full inclusion is successful. Is including children with special needs in the general education classroom beneficial to their education? Since we cannot expect to "cure" or "fix" these kids who have disabilities, how can we educate them to their fullest capacity? The goal of educating these students with disabilities should be no different than the goals of educating the students who are in general education, which is that we should educate them in such a way as to help them realize their full potential. This is where the problem and controversy arises in regard to students who have disabilities; how best to do this? To fully understand the issue of inclusion in the American Public School, we must examine the history of inclusion, the laws regarding the education of students with disabilities, and what some of the experts in education have to say about it. Only after a full examination of the facts can we decide for ourselves which is most beneficial and appropriate in the education of students with disabilities today: to fully include students with disabilities in the general education classroom or not.

Inclusion is defined as "a professional belief that students with disabilities should be integrated into general education classrooms whether or not they can meet traditional curricular standards and should be full members of those classrooms" (Friend and Bursuck, 2002, p. 505) . Just how did the practice of inclusion come about? Modern day special education began in the 1960's after several hundred years where we saw thinking change from the time prior to1800 where the disabled were thought to be "demon possessed"; to the time in the 1800's where public thinking was largely based on the misinterpretation of Darwin's Theory of Evolution and the disenchanting effects of the Civil War; to theearly 1900's where the work of scientists such as Freud, Kanner, and Binet began to impact the public thinking; to the post-war era of the 1950's when special education was shaped by the work of Bettleheim, Redl and Wineman, and Bower and many categories of disabilities became identified. From the 1960's through 1985 we saw a real take off in public funding, the beginning of many organizations to assist the disabled, and the emergence of a number of conceptual models of special education. Modern special education in the 1960's was from the point of view that because students with disabilities were so different in both their problems and abilities, that it did not make sense to treat all of these students the same. Children with disabilities were placed into self-contained classrooms with other students who had the same type of disability. The programs were categorical and the teachers were those with a degree in special education who had a specialty in a specific area of disabilities. The idea was to get these kids in school and get them in a program tailored specifically to their disability. In the early 1970's parents wanted to be assured of a suitable education for their children, so Public Law 94-142, the Education for Handicapped Act (EHA) , was passed which set guidelines for the services of special education (Friend and Bursuck, 2002) . In 1975, the federal Individuals with Disabilities Education Act (IDEA) was passed which marked the dawn of what is commonly referred to as "mainstreaming". This was a practice designed to get the students with disabilities out of their categorical classrooms and back into general education for "specials" (Music, Art, and Physical Education) , but for the most part the students were still separate and segregated within their schools. Proponents of mainstreaming were of the mind that social behavior does not occur outside of social contact and therefore, students with disabilities should be with their non-disabled peers. This involved the physical integration, functional integration, and social integration of the students. So, mainstreaming went from a time where we just wanted to get these kids in school, to a time where we mainstreamed them for "specials", to a time where they were mainstreamed to become a part of the school. Thus the argument became that if we can include these kids with disabilities some of the time, why not include them all of the time? This was the basis for our current trend toward full inclusion of all students with disabilities, regardless of their disability or abilities. Full inclusion is based on the rights of the students to be in the general classroom and the perceived social benefits that being in that classroom provides. There is, however, a difference in the social integration we saw in early mainstreaming versus that which we see in today's inclusion practices; the social integration of the 80's was done under highly controlled situations, while the social integration of full inclusion is not controlled. Understanding where the trend toward inclusion comes from is only a factual beginning in the understanding of whether or not inclusion is appropriate in the American Public School of today. What does the law have to say about the practices of inclusion? Have there been any tests of the law? How can this knowledge shape what is happening in our schools?

One can find commentary on the laws regarding inclusion on a website of the University of Northern Iowa which includes IDEA, passed in 1975, which states the current federal mandate regarding the laws on inclusion in the American Public School: "Each State must establish procedures to assure that, to the maximum extent appropriate, children with disabilities ... are educated with children who are not disabled, and that special education, separate schooling, or other removal of children with disabilities from the regular educational environment occurs only 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." 20 U. S. C. 1412(5) (B) (Website, Inclusive Education, <http: //www. uni. edu/coe/inclusion>, Feb. 27, 2003) . Dr. Susan Etscheidt, University of Northern Iowa professor and administrative law judge, says that some of the first legal analysis of IDEA came when the Supreme Court said that everyone is to be given a free and appropriate public education (FAPE) (Inclusive Education, 2003) . This is important to note in regard to the practices of inclusion. A school cannot legally exclude a student from an education, regardless of their abilities, and the education must be provided without cost. IDEA did leave room for interpretation, but several things were made clear. The responsibility would lie with each state. A child with disabilities can not be removed from a regular education classroom until such time as it is determined that a satisfactory achievement can't be made in a regular classroom even with the addition of supplementary aids and services. Just what is a satisfactory achievement? This is one area of hot debate. Is this strictly an academic achievement, or a social achievement? Who makes this determination and how do they make it? What are "supplementary aids and services"? These questions and their interpretation is what cause the controversy on whether or not full inclusion is appropriate. Amendments to IDEA, in 1977, helped to clarify a few of the issues—supplementary aids and services were defined, and general education teachers were included in the teams which write the Individualized Education Program (IEP) for each student so that they can be a part of the regular classroom (Inclusive Education, 2003) . This is where IDEA and our federal mandate stand currently. There is still plenty of room for debate. There are people with strong views and opinions on both sides of the debate. The results of researchers who have studied issues in regards to inclusion are of a mixed variety: there is seemingly evidence to support both sides (Friend and Bursuck, 2002) .

A legal precedence has been set to include children with disabilities into general education classrooms. IDEA, preceded by and including EHA, is based on several principles including zero reject (a rule against excluding any student) , nondiscriminatory evaluation (requires the fair evaluation of students to determine if a disability exists, and if so what kind and how extensive treatment should be) , individualized education (a tailored education for each child based on evaluation and enhanced by supplementary aids and services) , least restrictive environment (LRE--the education of students with disabilities along the side of students without disabilities to the highest extent possible) , and procedural due process (protects students rights and allows for necessary court actions) (Friend and Bursuck, 2002) . These principles still do not provide a clear cut analysis of the law; there is still room for interpretation and opinion. Specific cases which have been brought before the courts have helped to clarify the meanings of IDEA, as well as provide an argument on the side of full inclusion.

Several court cases demonstrate the difficulty in making a clear cut analysis of the law, as well as setting precedences for the practice of inclusion. The case of Brown v. Board of Education (1954) is discussed by Friend and Bursuck as a "case establishing the principle that school segregation denies some students equal educational opportunity ... . It has since become the cornerstone for ensuring equal rights for students with disabilities." (p. 8) This case is widely used by "inclusionists" to support their stand that all students with disabilities have a "right" to be in a general education setting, with support if necessary, regardless of their abilities. Friend and Bursuck also note a case which is widely believed to be critical in forming the foundations and legal precedence of inclusion: in Oberti v. Board of Education of Clementon School District (1993) , which dealt with a student with Down syndrome, it was ruled by the court and later upheld by the court of appeals that school districts are required to make the supports available to students with disabilities to fulfill their needs in the regular classroom, and furthermore that they can't exclude a student from a regular classroom because they learn in a different manner than other students (p. 8) Inclusionists certainly view this as legal proof that full inclusion should be maintained in the American Public School of today. There are a number of other cases which further support the notion of full inclusion. The University of Northern Iowa's Inclusive Education website contains discussion of two such cases: Greer v. Rome City School District (1990/1991/1992) and Board of Education v. Holland (1992, 1994) (Inclusive Education, 2003) . In the Greer case, the courts found that school officials had not made the necessary changes to a kindergarten curriculum to facilitate the inclusion of a child into a regular classroom and that the "whole range of supplemental aids and services" must be offered by the school (Inclusive Education, 2003) . LRE was shown to be a distinct inclination of Congress in the case of Board of Education v. Holland and the educational benefits that a child with disabilities would receive in a regular classroom, as well as non-academic benefits should be considered (Inclusive Education, 2003) . Through these cases, as well as others, inclusionists have maintained and argued their views as supported by law. The law has shown a penchant for the inclusion practices of ensuring equal rights for students, for not excluding students because of their abilities, for facilitating inclusion through the support of supplemental aids and services, and for always maintaining that LRE is the best way to assure a student gets the benefits of his/her education. These court cases are a strong support for the argument of inclusion.

In the journal Childhood Education, Douglas Fuchs and Lynn S. Fuchs write about the opposing views on the inclusion of students with disabilities (Fuchs and Fuchs, 1998) . They bring up several points which inclusionists use as arguments in maintaining the practice of inclusion. Inclusionists state the necessity of depending on a regular classroom to provide the instruction necessary for students to succeed in school, and eventually get a job—"teachers in these settings are experts in instruction ... To the fullest extent appropriate, teachers and students work on general education curricula and have an explicit understanding of the level of academic accomplishment necessary for success in regular classrooms" (Fuchs and Fuchs, 1998) . "Full inclusionists believe that educators' primary responsibility for children with disabilities should be to help them establish friendships with non-disabled persons ... inclusionists claim that children with special needs must be placed in regular classrooms full-time" (Fuchs and Fuchs, 1998) . Dorothy E. Hardin and Sally J. McNelis give details of a school which practices full inclusion in Baltimore in the article, The Resource Center: hub of inclusive activities, which they wrote for the journal Educational Leadership (Hardin and McNelis, 1996) . Hardin and McNelis speak highly of the success of full inclusion in this school with the support of a resource center which is used by all students, those with and without special needs—it is their conclusion that this would work in all schools (Hardin and McNelis, 1996) . It is the opinion of the inclusionists that full inclusion and the changes necessary to make it work is something to which we are "morally bound" (Fuchs and Fuchs, 1998) . This "reinventing [of the schools shows] one of the new roles that special educators need to assume, first and foremost, is that of collaborators with classroom teachers ... special educators ... should spend 100 percent of their time with mainstreamed students, with and without disabilities, who require additional help" ( Fuchs and Fuchs, 1998) . It is the stand of inclusionists that without full-time placement in regular classrooms, students with disabilities will not receive the type of academic teaching or the opportunities to make friends that is necessary to their success. They say that it is the moral obligation of our society to make the necessary changes in our schools, including full collaboration of general education and special education teachers, to allow full inclusion to be successful. Those who are against full inclusion see this in another light.

Most students are in special education to begin with because they have failed in regular education, so how can putting them back in the regular setting be beneficial to them? What evidence shows that full inclusion is the answer for all students? In a full general education classroom of students, a teacher must teach to an array of students. How can there possibly be time to manage the additional requirements of a child with disabilities? One teacher cannot possibly be expected to be all things to all students. Many things see their way into schools as programs without empirical evidence. Those who argue against the full inclusion of all students further maintain that a regular education teacher does not or cannot teach to the special needs of a child with disabilities which require much specialization, they are not trained to teach to that child, and there are no resources available for such. James M. Kauffman states in his book, Education Deform: Bright People Sometimes Say Stupid Things about Education, that "Some of us have maintained the position that although inclusion in general education in regular schools with support from special educators may work well for some students, such inclusion is neither feasible nor effective for all students" (Kauffman, 2002, p. 177) . Those who argue against full inclusion maintain that the needs of each student must be assessed individually; inclusion can not and must not be done in a manner which does not explore what is right for the individual.

Those who are in opposition to full inclusion have a very different view on Brown v. Board of Education (1954) than do their inclusionist colleagues. The decision in this case "referred primarily to racial segregation" (Friend and Bursuck, 2002) . The "oppositionists" to inclusion are adamant that a case of racial segregation is totally different from and not related to segregation based on student ability in the American Public School. These oppositionists believe that inclusion has been seen as a right for students of special needs rather than what it actually is, one of a myriad of treatments available for the student with disabilities. Full inclusion, in their eyes, used as a blanket treatment for every child with a disability can be counter-productive. Where it may work for some students, it can't and won't work for all and therefore should not be used in every case.

The oppositionists, like the inclusionists, use court cases as a basis to support their arguments on whether full inclusion should be used to educate all students in the American Public School. In Clyde K. v. Puyallup School District (1994) , as discussed on the University of Northern Iowa's site Inclusive Education, the determination was made that a boy with Tourette syndrome and attention deficit hyperactivity disorder could be put into a special education setting, outside of the regular classroom,because he wouldn't benefit in a social or academic way from being in a general education setting—the court further stated that the school had met the demands of IDEA by providing the necessary supplementary aids and supports which were to no avail (Inclusive Education, 2003) . Thus, the oppositionists conclude IDEA suggests that inclusion is not the best solution for some students; therefore inclusion must not be applied in all cases. In Fort Zumwalt School District v. Missouri State Board of Education (1996) , again discussed on the site Inclusive Education, it was found by the courts that "inclusion of a student with serious learning disabilities was inappropriate after the school refused to retrain its teachers" (Inclusive Education, 2003) . Here we see the oppositionists argue that the courts agree that inclusion for all students is not always appropriate. The use of these court cases by the oppositionists to support their views is used in a similar fashion as the way in which the inclusionists used court cases to support their views. We can see that the IDEA laws and subsequent court cases are open to a broad range of interpretations and that both sides use them and translate them to their best advantage.

To not use full inclusion as a blanket treatment for all students with disabilities is the basis for the argument presented by the oppositionists. Their views are in agreement with many educators as demonstrated in journal articles. In the Journal of Disability Policy Studies, Jean P. Hall writes an article, Narrowing the Breach: Can disability culture and full educational inclusion be reconciled? , where she states "People and organizations favoring inclusion, however, are overlooking the value of the disability culture that is fostered when children with disabilities have the opportunity to associate with and learn alongside other individuals who share similar identities and life experiences ... changes to the existing system rather than a movement to full inclusion will be more effective in supporting disability culture and , ultimately the needs of children with disabilities" (Hall, 2002) . Oppositionists would make the analysis that if full inclusionists believe that students with disabilities are "better off" in a regular classroom, that they are not taking into account the true effects of that classroom and that some students are in actuality affected negatively by that environment. Oppositionists maintain that the education of a student should always be a top priority when placing a child, or writing an IEP for a student. This opinion is supported by Tom E. C. Smith and Carol A. Dowdy in their article for Childhood Education, Educating young children with disabilities using responsible inclusion (Smith and Dowdy, 1998) . Smith and Dowdy say, "Placing children with disabilities in general education classroom settings, without regard to individual needs, because it reflects current ideas about best practice, does not support the least restrictive environment concept nor the goal of providing appropriate educational programs for all children" (Smith and Dowdy, 1998) . The analysis of the oppositionists here concludes that education is to be accounted for first and is more important, ultimately, than any current trend in education. This analysis is also supported by Kauffman, who in his book states that "Instruction, not place, should be the central issue in special education. Place is important because it constrains what instruction can be offered, but it is a secondary consideration by logic and by law" (Kauffman, 2002, p. 183) . The oppositionists inherently believe that full inclusion is wrong and that students are not necessarily better off in a regular educational setting; in addition, they believe that education of each student should always be the driving force in determining the IEP and education of a student with disabilities, whether in a general education setting or not.

Looking at inclusion from both sides, we see biases and opinions. We see that both sides are guilty of measuring the effectiveness and using units of analysis which can be biased toward their agendas. We must not let these biases, however, cloud the real issue. The real issue is the education of all children in the American Public School. All children's educational needs should be addressed individually. What is often seen missing from this debate is the effect that full inclusion has on the non-disabled students in the classroom. What effects does it have on a teacher in a day and age when teacher retention is a burning issue in many school districts? We must remember that our decisions in regard to the education of students with disabilities will affect real children and are not just hypothetical situations. We must not forget that if we follow the path the inclusionists would have us follow, that we get rid of an array of services for students with disabilities leaving only two real options: full inclusion, or no school. There would be no middle ground. What happens then when full inclusion does not work for a student? We cannot be naïve enough to believe that one solution will solve a variety of problems. In education, one size does not fit all. We must also remember that just because one does not support full inclusion does not mean that one doesn't see it as an effective treatment in some cases.

It is the opinion of this author that to institute full inclusion in the American Public School would be to do a disservice to our students. We mustn't look at only limited factors, that of student rights and social benefits to students, in determining the appropriate education plan for a student with disabilities. Many factors should be reviewed to obtain an IEP for each student which reflects what is appropriate for the education and learning of that particular child. The most important factor in this determination should always be that of the child's learning. Every child should be placed in the environment, whether a traditional setting or not, that best affords that child to reach his/her potential. We should also remember that when we place a student, that the needs of other students in that classroom also need to be considered. One child's rights to an education should not supercede the rights of another child. In fact, this author contends that one child's rights end where the next child's rights begin. We must consider that a child who is fully included in a classroom may not be fully served in that classroom. Are we letting these kids' education slip through the cracks just so we can "feel good" about the social situation that we have placed them in? Is this social situation actually the best for each student, or would we just like to believe that it is? Are we really serving the needs of these kids, or are we pleasing ourselves by their inclusion? Full inclusion is right for some students, and not for others. We must learn to put the needs of the child first, making accurate assessments of their needs and abilities, and passing policies which protect them from "social do-gooders". We must ensure the rights of all students, both abled and disabled, to receive the education to which they are entitled by law. Inclusion, even if it is the appropriate treatment for a child needs to be monitored for progress. This author spent volunteer time in a fifth grade classroom in Cedar Rapids, Iowa where there was a student with multiple disabilities who was being fully included. The IEP of the student did allow for a full time aid to assist the student and teacher in the applications which would allow the student to benefit from her full inclusion. This all looked good on paper, but in reality this was disastrous—not only for this student, but also for other students, one in particular, in that classroom. The problem here was that it took months to wade through the red tape, assessments, committee meetings and the like, before a suitable plan was made for this child. Once the plan to hire an educational aid to work with the child and her teacher was made and implemented, the aid quit after only three days because of the difficulty of the situation. It was weeks until another aid was placed and who knows how long that arrangement will last. In the meantime while all of this was going on in the background, the child was spending her days in a general education classroom with very little in the way of supports. The teacher had another student assigned to be the permanent "helper" of this child—the child was expected to help the disabled student with her work, help with the discipline of said student, and to be an advocate for this child in the classroom. This was done under the guise of education. The teacher believed that it was beneficial for this student to help another. There is nothing wrong in teaching one student to help another, or to be empathetic toward his/her situation, but it is entirely another issue in making one eleven year old child responsible for another child in the classroom. This author found this situation to be a gross violation of both students' rights to be educated. We must not only place a student where they will be best served, but we must also make arrangements for what happens to that student in the time that the appropriate treatment is being arranged. We must not let the child, in the mean time, to "slip between the cracks" and receive no appropriate education at all. It is because of this experience, as well as the examination of the history, the laws, and the views of educators that this author believes that full inclusion should only be used as one of many treatments for a child with disabilities, not as an answer for all.

There are strong points of law, court cases, and expert opinion to support both sides of the inclusion debate. We know that more and more students with disabilities are spending their school days in general education settings. The debate on the issue of inclusion will continue for some time. We must remember what we have learned from both the proponents of full inclusion, as well as those who oppose it. The inclusionists are right to bring special education out into a new light, to consider the rights of children and the social ramifications of their placement. The oppositionist would ask, is this enough to determine the placement of a student with disabilities? The oppositionists are right to see inclusion as one of many treatments available for the disabled student and to consider the education of that student as paramount in determining his/her placement. The inclusionists would ask, where are the rights of the student? The history and subsequent laws of inclusion can help us to understand how we got to this point. Where will we go from here? When all is said and done, it still comes down to the lives of children. We cannot forget that how we proceed in the issue of inclusion will dramatically effect these children and their futures. What if it was your child?

References

Books

Friend, Marilyn and Bursuck, William D. (2002). Including Students with Special Needs, A Practical Guide for Classroom Teachers (3rd ed.). Boston, MA: Allyn & Bacon, 2002.

Kauffman, James M. (2002). Education Deform, Bright People Sometimes Say Stupid Things about Education. Lanham, Maryland: Scarecrow Press, Inc.

Journals

Fuchs, Douglas and Fuchs, Lynn S. (1998). Competing visions for educating students with disabilities: inclusion versus full inclusion. Childhood Education, Midsummer 1998 v74 n5 p309 (8).

Hall, Jean P. (2002). Narrowing the breach: can disability culture and full educational inclusion be reconciled? Journal of Disability Policy Studies, Winter 2002 v13 i3 p144 (9).

Hardin, Dorothy E. and McNelis, Sally J. (1996). The resource center: hub of inclusive activities. Educational Leadership, February 1996 v53 n5 p41 (3).

Smith, Tom E.C. and Dowdy, Carol A. (1998). Educating young children with disabilities using responsible inclusion. Childhood Education, Mid-Summer 1998 v74 n5 p317 (4).

Websites

University of Northern Iowa. (1999). Inclusive Education.

Back to Course Page

When considering provision for children with special educational needs and disability (SEND) in England, the Warnock committee’s report (DES 1978) was a significant landmark towards ‘inclusive’ education. This committee suggested not only the concept of special educational needs (SEN), but also encouraged the principle that children with SEN could be educated in mainstream schools or non-special schools. Also, the committee introduced parental participation in decision-making for their children with SEN. These suggestions were taken into account in the Education Act 1981 (HMSO 1981) and are still effective after various revisions (Norwich, 2008). ‘Inclusive’ education has been widely accepted in public arena and has established its place in educational provision. On the other hand, some ambiguities of ‘inclusion’ are still left to be discussed. In this assignment, the areas which remain as dilemmas within inclusive education are going to be discussed, by identifying influential aspects and processes which can be used to develop inclusive practice.

The Warnock report and the medical model
The starting point of inclusive education is first considered. Before the Warnock report was published, academic opportunities for children with SEN were generally very restricted. Unfortunately, they were thought of as not capable of being educated, maladjusted or sub-normal. Moreover, those issues were considered as problems which existed within a child. Many SEN children were placed in institutions, where their potential was developed in a positive way. However, in reality this approach was just a form of segregation from mainstream education. The Warnock report was the first time it was suggested that children could be integrated into mainstream education, if their special ‘needs’ were addressed in order to overcome their difficulties, rather than as children within a medical setting. It is also important to point out that such provision was under certain conditions; it was in accordance with the parents’ wishes, compatible with the education of other children in the class, and allowed efficient use of resources (Bibby and Lunt 1996). In one sense, policy moved away from the view of a ‘medical model’ of disabilities.
Instead, the ideals of the Warnock report and the subsequent Education Act 1981 rather favoured a movement towards ‘integration’, not towards ‘inclusion’. Oliver (1996) thought that the commitment of the governmental and educational administrators was incomplete to ensure its implementation. Norwich (2008) considered that the initiative which Local Education Authorities (LEAs) took was to increase resourcing to try to accommodate many children with SEN in mainstream schooling. However, this is again another form of integration, not inclusion.
As a result of the inclusion movement, special school populations started to decrease and some schools closed down as a result; later, this would cause some dilemmas in the support system. Nevertheless, this reflected the start of inclusive education, even though it was to ‘integrate’ SEN children into mainstream education. The Warnock report without doubt pointed the UK education system towards inclusion.

Categorisation
The Warnock report was introduced positively with an emphasis on providing for the needs for children with SEN, rather than looking for deficits in children. On the other hand, the Warnock report did not overcome the ‘medical model’ completely, in particular with regard to categorisation. The issue of categorisation is discussed here. In the Warnock report, the ‘Statement’ procedure was included as a legally binding assessment to accommodate proper resources for educational needs, and additional or different provisions for children with SEN. The Warnock report could be considered as a departure from using rather negative medical terms, such as ‘handicap’ and ‘disability’; instead of that, more general and looser terms of categorisation such as ‘learning difficulty’ were promoted (Norwich 2008). In short, it was just a substitution of terminology.
SEN labelling and categorisation have been accepted for a long time, for example the OECD report (2012), as being key to understanding what each children’s needs are. Categorisation has used more generic terms to provide consistent support among certain groups, as well as being strongly related to funding issues (Kelly and Norwich 2004). There is a problem here; even though this categorisation is used in a positive way to provide support, the categorisation can sometimes be treated negatively. The nature of the categorisation has a risk of turning into a ‘label’ for learners’ difficulties. And a label is, according to Freeman (2013), simply based on assumptions and never evidence, giving authority to professionals, and then resulting in limiting children’s expected capability. Even though expectation should be equally high for all learners, a label may be used as justification or as an excuse for a learner’s failure to reach targets, instead of finding a way of improving attainment. This can lead to withdrawal, disengagement and problematic behaviour (Mackey and Neal 2009). At the heart of labelling is the belief that those within a certain SEN ‘box’ are all the same, with the same needs and therefore normalising individual needs. Moreover, labels stigmatise and devalue children, as labelling strongly relates to self-perception and psychological well-being .The impact of the school setting and others’ views of educational ability are strongly co-related with self-perception (Kelly and Norwich 2004). Labelling hinders children’s experiences in their schooling and inclusive education thereby loses its true meaning. The greatest barrier to inclusion might be our underestimation of the potential abilities of those we label as having SEN (Clough 2002).

National Curriculum and Marginalisation.
Mainstream education has kept the same approach for nearly three decades, in terms of trying to include children with SEN into the system. This is another barrier for inclusive education. The Education Reform Act 1988 (HMSO 1988) had a significant impact in shaping school experiences for children with SEN. This Act enhanced free parental ‘choice’ of school, and also introduced the National Curriculum to focus on levels of standardised attainment; to maintain this, Key Stages and Standard Attainment Tests (SATs) were introduced. Reflecting parental choice and a consumerist approach to education, schools were driven to a market-based education system and concentrated on raising standards and attainment (Tomlinson 2008). There followed league tables for schools and the Office for Standards in Education, Children’s Services and Skills (Ofsted) inspection system in the 1990s, echoing this movement. The issue here was that while the National Curriculum introduced for all pupils the right to access the same curriculum, it did not take account of children with SEN.
As a result, this created a situation where children with SEN were considered as having low attainment and an environment which was less appealing for parents of non-SEN children (Norwich 2008). Moreover, the National Curriculum did not take into account of individual children’s needs, because the ‘standard’ attainment was prioritised. Furthermore, schools were obliged to follow the National Curriculum, which was not flexible initially, while at the same time schools had a responsibility to cater for children with SEN. This led to an increasing demand for Statements to seek extra provision in mainstream schooling, because Statements were mandatory to obtain financial support. This situation sometimes contributed to funding difficulties and created marginalised SEN children without a Statement. It also created marginalised children with a Statement, for example, those with a behavioural problem who were placed in a normal situation and were permanently excluded, because of the need to conform with the National Curriculum (Audit Commission 2002). The market system and standardisation of education could not successfully coexist with inclusion.
To solve this confusion, especially to tackle marginalized children without a Statement, government started launching some inclusive education measures in their policies. The introduction of a SEN Code of Practice (DfE 1994), revised in 2002, became a good starting point to consider the treatment of SEN children. In addition, the Labour government from 1997 sought a wider inclusion agenda in the education system and introduced some positive measures, such as ‘Excellence for all children’ (DfEE 1997) and the Special Educational Needs and Disability Act 2001 (SENDA) (HMSO 2001). Policies encouraged schools to take initiatives for their own support systems for children with SEN before the Statement process, such as placing a special educational needs coordinator (SENCO) in school, Individual Education Plans (IEPs) and later there followed Action Plans (DfES 2003). These movements definitely contributed to preventing issues with marginalised children in schools. Moreover, and importantly, the most significant initiative for inclusive education was that the government introduced special adaptations in the National Curriculum for children with ‘learning difficulties’ (QCA 2003). Before these adaptations, the National Curriculum did not have the flexibility to provide an individual curriculum for individual needs and targets in education (Norwich 2008). Schools and systems had to change their attitudes to deliver the right education for individual children’s needs to be met, rather than children needing to fit within the curriculum in order to be included. This is a clear shift towards the ‘social model’ of disability.

The social model
The shift of thinking towards the ‘social model’ of disability is an important aspect when considering inclusive education. If the ‘medical model’ perspective saw children’s difficulties as resulting from children’s own characteristics, by contrast the social model of disability sees them as the outcome of social realities (Clough 2002). To create an inclusive environment in which children with SEN can participate, the curriculum should have an aim, which is an ‘objective’ that is ‘adjusted’ or ‘special’ to reflect individual needs. Therefore schools and teachers need to give attention to regular assessment and revision of learning within the framework of the curriculum, with the view that the ‘curriculum’ exhibits issues, not the learner. IEPs can support this approach.
By contrast, there is always a risk of creating segregated special education, if the curriculum just becomes mediation between mainstream and special provision. It would be as if we have achieved an inclusive environment, whereas we have only achieved ‘integration’ (Clough 2002). Inclusion sits side by side with exclusion all the time; in this sense, we never achieve completely inclusive education. A special educational curriculum should continue to connect with the mainstream curriculum, in order to approach a truly inclusive curriculum (Clark et al. 1998).

Rights
While appropriate delivery of the curriculum is vital for inclusive education, the whole school ethos, institutional culture and role of pedagogy are equally important in creating an inclusive environment (Clough 2002). Therefore, considering inclusion only within the sphere of children with SEN might limit the possibilities of inclusion itself. Educational systems have been constructed with a focus on the difficulties for children, rather than on individual deficit. The cycle of deprivation comes from social disadvantage, and inequality has resulted from institutional inequality, sometimes in the form of a hidden curriculum (Tomlinson 2008). The ‘social model’ of disability regards inclusive education as connecting with an inclusive society and the removal of all forms of oppression (Clough 2002). Therefore while the curriculum has a crucial role in accessing an inclusive education, maximised participation in the community and culture is an essential element for inclusive education (Clough 2002).
According to Booth (1996), exclusion is not simply about disability, it is about the inability to participate in mainstream culture and community. The United Nations Convention on the Rights of the Child (UNCRC) 1989 (UN 1989), the Salamanca Statement (UNESCO 1994) and Education for All (UNESCO 2000) have promoted a universal awareness of issues and also influenced the UK political agenda; access to an appropriate education is now an ethically and socially fundamental element for human rights, equal opportunities and participation. Those rights will lead to social and educational inclusion. Inclusion has been even more promoted in the public and political arenas, and inclusion has echoed the views of the ‘social model’ of disability rather than the views of the ‘medical model’ of disability. Inclusion has set a philosophical argument that any children with mental, physical, or emotional handicaps are entitled to access to education within the mainstream of public education. Therefore, the more inclusive is educational progress, the more inclusive is societal progress. According to Hunt (1966), the problem of disability lies not only in the impairment of function and its effect on us individually, but more importantly in our relationship with normal people.

The whole approach
Educational inclusion is irrevocably connected to social inclusion. Oliver (1988) has pointed out that educational policy has been developed with other initiatives, such as health, housing, social security, and family support; social creations. Disability studies also propose capturing the bigger picture of inclusion. Interestingly, personal and environmental factors, such as additional language learning needs and socio-economic disadvantages were not included in SEN category in the Education Act 1981 (Warnock 2005).
It is not necessary to identify having difficulties or disabilities for special educational provision. Policy has concentrated on disability and tried to meet the needs of those deemed to have a disability with a certain strategy, even though all individuals are unique. Actually, we need a view of abilities within individual children. Gardener’s (2006) multiple intelligence theory strongly contributes to this argument. Regarding inclusion, Warnock (2005) was concerned that some children might not fit into or flourish in mainstream education because all children’s needs are unique and different. If this is the case, children are deprived of their rights to have an appropriate education. The current Government policy is to encourage the maximum level of integration of pupils with SEN into mainstream schools and to try to provide special support to facilitate this. Conversely, if some students do benefit from specialised teaching and extra resources in special schools, then it might be asked whether there is a benefit of integration into mainstream schools for children with SEN, and this is an individual choice (Warnock 2005).
When considering an appropriate education, it is an entitlement of parents and children with SEN to be involved in decisions for special educational provision; and there is also the obligation of the authorities to provide adequate resources to ensure that children with SEN can have an education appropriate to those needs, to become full members of our society (Borsay 2005). This echoes with the Every Child Matters (ECM) (2004) agenda.
To summarise, inclusive education is not an argument for accessing mainstream education for the students who have previously been excluded. Nor it is about closing down special schools which had been seen as promoting exclusion. ‘Inclusion’ should be valued as a process in which existing school systems can change; such as taking into account the environment, curricula and teacher’s roles, to further the participation of all learners (Barton 1997).
Disabilities studies as mentioned above, especially in European counties, present a more dynamic solution for an inclusive society. The recent European disability strategy suggested that the concepts of inclusion in mainstream education must target supporting people with disabilities to develop their biographies in the context of ‘normal’ social institutions and places, because those are the decisive conditions for their participation. Moreover, to appreciate disability, welfare and educational policies need to understand the risks of discrimination, continuing to rely on medical and psychological interpretations and define and measure impairment with reference to specific impairment groups, but not with any mindset of oppression or discrimination (Barnes 2008). As a result, we identify the realities and difficulties of people’s lives as well create the link between individual biographies and social barriers; this is the perspective of a life course approach (WHO 2000). Taking the life situation of people with severe disabilities and complex needs as a starting point, the life course oriented approach makes it possible both to collect data on patterns of social protection and public attitude and to identify risks of discrimination in each stage of their life (Schade, et al. 2008). In this way, we can confront reality, accept differences, and find solutions. Children’s difficulties exist in reality. This also echoes the ECM agenda (2004).

Flexible provisions
Accepting individual differences and needs leads to inclusive education. An acknowledgement of the diversity of the learning needs of all learners and flexibility in pedagogy is the starting point to consider ‘inclusive education’ (Wedell 2008). Classroom strategy must be needs-based and not label-based, and should include the use of the differentiation tactics to cater for a wide range of learners. Teachers can build up a picture of a learner’s difficulties, their learning needs, which interventions have worked for them in the past and which have not, and the way forward. Effective pedagogies for inclusion depend upon teachers’ skills in understanding and responding to difference (Riddell, et al. 2006). Of course, this depends on class size and class subjects, and moreover the collaboration with the Teaching Assistant is vital element (Goepel, et al. 2014). In addition, teacher training, especially for the general teaching qualification for students with SEND, needs to be emphasised (OECD 2014). Realistic and flexible approaches are required for an inclusive environment, such as activity-based learning, self-directed learning, practical hands-on approaches, thematic approaches to topics and open-ended tasks (Goepel, et al. 2014). Similarly the assessment for learning strategy (Black and William 1998) is considered strongly effective to create inclusive teaching, including feedback; meta-cognition and self-regulation; peer mentoring and peer working; well-structured and well-targeted questioning; and small group working. Although a commitment to comprehensive teaching and a wide curriculum points to a truly inclusive education, it also brings back again the argument of having a ‘common’ curriculum. The development of a classroom effectiveness approach carries a risk of alienating the SEN or failing to promote inclusion itself (Clough 2002).
The fundamental concept of inclusion has been developed as a ‘common’ approach, and in particular it has developed alongside the difficulties of the class and the management of class resources; it has also identified a range of questions related to governance, curriculum, and detection and placement for individual needs. This is the way forward to inclusive education (Norwich 2008). The issue is not about treating everyone the same; what is important is that everyone should be treated equally: ‘realising these entitlements would look very different for different children in different areas, but the quality of their opportunities would not be different’ (Wadell 2008).

Children and Families Act 2014
The future of inclusive education is now considered, in relation to the introduction of the Children and Families Act 2014 (HMSO 2014). There are clear signs of improvement around a good number of processes which are the central aim of this reform, such as enhancing the child and family centred view. Improvements in the quality of the support which children will receive through the Local Offer, Personal Budget and education, health and care (EHC) plan are promising, compared to the previous system. Yet some families still think children and young people do not have a say in the support planning process and that professionals still lead the services, and there is no perceived difference in qualities of life or health (Craston et al, 2014). Involvement in the decision making process, moreover allowing young people to think what is best for them, should be a vital role in decision making. Early intervention, multi-agency work, parental views and the children’s own views should be coordinated as part of a comprehensive program, to provide efficient support bearing in mind the future perspective of their life, leading to a life course approach. It is still too early to make any judgement on the outcome of this new Act; in addition, inclusive education involves a process of reform and restructuring as a whole (Mittler 2000). Inclusion will work in an environment with proper accommodation for sufficient support, with adequate resources and funding, where decisions are truly child-centred.

Conclusion
Without any doubt, ‘inclusive education’ and inclusion as a whole are ethically, socially and politically essential rights to be a member of society. However, inclusion has been developed with dilemmas between the ‘medical model’ and the ‘social model’, together with categorisation and marginalisation, and will continue to develop with dilemmas. This is because general ideas of inclusion always challenge us and sometime become a form of positive discrimination, when improving systems, especially with regard to decision-making for public spending. The ‘official’ terminology is sometimes too conceptualised, and is not current with the ideas and thinking of issues involved in SEND. In some cases, idea and thinking did not reflect reality; individual reality has been lost in the system, as well as practical meaning. So inclusion becomes far away from reality. Inclusion can be used as moral and political rhetoric in Western counties, but should be considered as the movement and process which has resulted from current beliefs, and different local struggles (Clough 2002). In this way, inclusive education can capture ideas from the real life and experiences in each child. Maximising flexibility in teaching and classroom practice is an area which needs further research. Promoting attitudes of accepting realities and recognising differences for individual needs are vital areas of inclusive education. (Word counts: 3,305)

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