A key phrase from the legislation to keep in mind is this, “…only when the nature or severity of the disability of a child is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily” (20 U.S.C. § 1412(a)(5). What does satisfactorily mean? This kind of verbiage is unfortunately a part of legalese and makes the provision of a FAPE problematic. Indeed, as this chapter is being written, the United States Supreme Court has heard a case (but has not issued a ruling) that asks essentially how much progress a student is to achieve (Forest Grove School District v. Student, 2016). At this early stage, it appears the justices of the court are leaning towards a ruling in favor of the parents, even though the district contends that the small progress the student was making is in line with the language in the IDEA and the seminal FAPE case Board of Education of the Hendrick Hudson School District v. Rowley (1982).
What is satisfactory progress and can it be achieved for all students in the general education setting? The debate being held in the Supreme Court in the case mentioned above, is between “more than trivial” (the district’s definition) and “meaningful” (the parent’s definition). As previously noted, the court is leaning in favor of “meaningful.” So, what does the research say about inclusive environments and whether or not they can deliver meaningful benefits to students with disabilities?
Kavale and Forness (2000) describe the efforts on both sides of the reform struggle and the dearth of evidence to support either full inclusion or a continuum of services. Though, in the few studies covering this issue, they indicated a continuum of services that fit the needs of the child has been shown to be more effective. Upon closer examination, they found that’s students with high incidence disabilities (learning disability, emotional disturbance) made smaller gains in the inclusive environment than their nondisabled peers. In essence, the achievement gap continued to grow in the inclusive environment. Interestingly, students with low incidence disabilities (intellectual disability) maintained growth curves equal to nondisabled peers in an inclusive environment. Further, a synthesis of randomized control trial studies by Fuchs and colleagues (2015) showed that scores for at-risk students on math assessments were significantly higher at post-test for students receiving state-of-the-art math instruction delivered in a small-group setting, as opposed to those receiving “inclusive” math instruction in the general education classroom.
Well, the good news is that specialized instruction delivered by trained staff in small groups is effective at narrowing the gap between students with disabilities and their nondisabled peers (Kavale & Forness, 2000; Fuchs et al., 2015). It does not, however, speak to the full inclusion of all students regardless of their needs either legally or regarding their achievement.
Due to the advocacy efforts of the aforementioned organizations and researchers (e.g., Stainback & Stainback, 1985) and misinterpretation of key aspects of legislation, inclusion is here and likely will be for some time unless key stakeholders (e.g., you, your administrator) seek out the research to inform the most effective instruction of students with disabilities. Until that time, it is very likely you will be faced with providing instruction, or assisting in the inclusion of students with disabilities in the general education classroom. Indeed, previous research has noted problems with inclusive practices as a whole and a disconnect between the views of classroom teachers’ and the those of school administrator (Cook, Semmelb, & Gerber, 1999). Cook and colleagues suggest that administrators tend to have an “optimistic” (pp. 206) view of inclusive practices, which may be incongruous with the views of the teachers who have to work under this model.
The key takeaway from all of this, and the law, is that special education is individualized instruction. Universal design for learning is a great concept and will likely help students of all ability levels achieve, but it is not necessarily the global fix for all students (Fuchs et al., 2015). Through careful progress monitoring (as described in Chapter 2) it would be relatively straightforward to determine if learning in an inclusive environment derived satisfactory achievement as compared to when learning in a small-group setting with a trained special educator. For example, it may be that in a well-structured and functioning co-teaching environment, a student with disabilities may demonstrate achievement consistent with gains made in a resource room, in which case, the inclusive setting would be the preferred placement. While the research may be lacking specific investigations comparing inclusive settings to special-education settings, there are a great number of studies that elf-regulated strategy instruction. In general, the descriptions included here are an overview as some of these strategies will be documented later in the book in moredetail have been conducted in an inclusive setting that may be able to inform a selection of best practices for the setting. The remainder of this chapter will discuss three broad strategies for including students with a variety of disabilities in the general education classroom: co-teaching, peer-mediated instruction, and self-regulated strategy instruction. In general, the descriptions included here are an overview as some of these strategies will be documented later in the book in more detail.