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Inclusive Education: Practical Implementation Of The Least Restrictive Environment - Isbn:9780834208063

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  • Book Title: Inclusive Education: Practical Implementation of the Least Restrictive Environment
  • ISBN 13: 9780834208063
  • ISBN 10: 0834208067
  • Author: Lissa A. Power-deFur, Fred P. Orelove
  • Category: Education
  • Category (general): Education
  • Publisher: Jones & Bartlett Learning
  • Format & Number of pages: 361 pages, book
  • Synopsis: One excellent resource that explores the topic of selfworth is Reclaiming Youth at Risk: Our Hope for the Future (Brendtro, Brokenleg, & Van Bockern, 1990). These authors discuss a philosophy of belonging based upon the Native American ...

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Scheffer, Victor B. – National Wildlife, 1973

Discusses the seal controversy using the harp and Alaska fur seals to illustrate the two distinct issues, i.e. conservation (the effect of killing upon the animal population); and two, morality (the effect of killing upon the human spirit). Factual information combines with personal philosophy. (LK)

Descriptors: Conservation Education, Environmental Education, Moral Issues, Natural Resources

Power-deFur, Lissa A.; Orelove, Fred P. – 1997

The 19 chapters of this book address theoretical and practical aspects of the development and implementation of inclusive education programs. Chapter titles and authors are: (1) "Inclusive Education: The Past, Preset, and Future" (Lissa A. Power-deFur and Fred P. Orelove); (2) "Inclusion and School Restructuring: Meeting the Needs of All Children"…

Descriptors: Agency Cooperation, Behavior Disorders, Change Strategies, Curriculum Development

Malone, Bobbie; Fajardo, Anika – 1998

This teaching guide seeks to add to and enhance the teaching of Wisconsin history and culture in public and private schools. Designed with the fourth-grade classroom in mind, studying state history with this guide becomes a real investigation that demonstrates the dynamic relationship Wisconsin's inhabitants share with the past. The activities in…

Descriptors: Cultural Context, Grade 4, Intermediate Grades, Land Use

Source:

eric.ed.gov

Articles

Using Natural Language Processing to Assist the Visually Handicapped in Writing Compositions

Using Natural Language Processing to Assist the Visually Handicapped in Writing Compositions
  • Jacques Chelin Affiliated with Department of Computer Science and Software Engineering, Concordia University
  • . Leila Kosseim Affiliated with Department of Computer Science and Software Engineering, Concordia University
  • . T. Radhakrishnan Affiliated with Department of Computer Science and Software Engineering, Concordia University

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Abstract

Over the last decades, more and more visually handicapped students have attempted post-secondary studies. This situation has created many new challenges. One of them is the need to study text and electronic documents in depth and in a reasonable time. Blind students cannot flip through the pages of a book, skim through the text or use a highlighter. In this paper, we propose a solution in the form of an experimental prototype and show how natural language processing techniques can profitably assist blind students in meeting their academic objectives. The techniques used include the automatic creation of indices, passage retrieval and the use of WordNet for query rewriting. The paper presents a technology application of a practically usable software.

The system was evaluated quantitatively and qualitatively. The evaluation is very encouraging and supports further investigation.

CSUN’s 20th Annual International Conference Technology and Persons with Disabilities, Los Angeles (March 2005)

Cowan, N. The magical number 4 in short-term memory: A reconsideration of mental storage capacity. Behavioral and Brain Sciences 24, 87–185 (2001) CrossRef

Hodges, J. Yie, S. Reighart, R. Boggess, L. An automated system that assits in the generation of document indexes. Natural Language Engineering 2, 137–160 (1996) CrossRef

Manning, C.D. Schütze, H. Foundations of Statistical Natural Language Processing. MIT Press, Cambridge (1999) MATH

Miller, G.A. The magical number seven, plus or minus two: Some limits on our capacity for processing information. Psychological Review 63, 81–97 (1956) CrossRef

Orelove, F. Power-deFur, L. Inclusive Education: Practical Implementation of the Least Restrictive Environment. Jones and Bartlett Publishers (1997)

Porter, M.F. An algorithm for suffix stripping. Program 14(3), 130–137 (1980)

Shimizu, T. Smoliar, S. Boreczky, J. AESOP: An Outline-Oriented Authoring System. In: Proceedings of the Thirty-first Annual Hawaii International Conference on System Sciences, Hawaii, January 1998, pp. 207–215 (1998)

Wacholder, N. Evans, D.K. Klavans, J.L. Automatic identification and organization of index terms for interactive browsing. In: International Conference on Digital Libraries. Proceedings of the 1st ACM/IEEE-CS joint conference on Digital libraries, pp. 126–134 (2001)

About this Chapter Title Using Natural Language Processing to Assist the Visually Handicapped in Writing Compositions Book Title Advances in Artificial Intelligence Book Subtitle 19th Conference of the Canadian Society for Computational Studies of Intelligence, Canadian AI 2006, Québec City, Québec, Canada, June 7-9, 2006. Proceedings Pages pp 300-311 Copyright 2006 DOI 10.1007/11766247_26 Print ISBN 978-3-540-34628-9 Online ISBN 978-3-540-34630-2 Series Title Lecture Notes in Computer Science Series Volume 4013 Series ISSN 0302-9743 Publisher Springer Berlin Heidelberg Copyright Holder Springer-Verlag Berlin Heidelberg Additional Links
  • About this Book
Topics
  • Artificial Intelligence (incl. Robotics)
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  • Pharma
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eBook Packages
  • Computer Science
Editors
  • Luc Lamontagne (18)
  • Mario Marchand (19)
Editor Affiliations
  • 18. Departement of Computer Science and Software Engineering, Laval University
  • 19. Département IFT-GLO, Pavillon Adrien-Pouliot, Université Laval
Authors
  • Jacques Chelin (20)
  • Leila Kosseim (20)
  • T. Radhakrishnan (20)
Author Affiliations
  • 20. Department of Computer Science and Software Engineering, Concordia University, Montreal, Canada
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W - M School of Education

Creating a Master Schedule that Supports Inclusive Practices
By Dale Pennell, C.A.S.
May/June 2012

A wise school principal recently said: Our inclusion program has never been as good as it should have been because we had other priorities in our scheduling. Now we realize that the education of all students in our building must take top priority. We can provide more and more intensive services for these students if we schedule better. The tail can’t wag the dog! (McLeskey & Waldron, 2000, p. 41)

Does your school’s master schedule limit the effectiveness of your efforts to include students with disabilities in a meaningful way that supports their academic progress? Following are steps you may take to ensure that the tail doesn’t wag the dog as you develop your next master schedule.

  1. Create a matrix. In column 1, list the names of included students who need support from school-based special education staff. At the top of the remaining columns, list the general education courses in which these students will be enrolled. Use the matrix to mark the courses in which each student will require in-class support (see Table 1: Matrix for Identifying Students’ Direct Service Requirements/Number of Teachers/Number of Course Sections Required ).
  • Use the completed matrix to determine staffing needs (visit http://www.doe.virginia.gov/special_ed/regulations/state/regs_speced_disability_va.pdf for Regulations Governing Special Education Programs for Children with Disabilities in Virginia on page 90.
  • Determine the number of sections into which to schedule students with disabilities for each course. Ideally, the percentage of special education students assigned to each course/section should reflect the special education demographics of the school (Capper, Frattura, & Keyes, 2000). In reality, no more than 20% of the students in a class should require special education services (Walther-Thomas, Korinek, McLaughlin, & Williams, 2000).
  • Identify the general education teachers in whose classes direct services will be provided and the periods during which the students will be included.
  • Select the special education personnel who will be assigned to each inclusive course/section in which students with disabilities require instructional support.
  • Designate common planning periods for participating general and special education teachers (see Table 2: Sample Co-Planning and Co-Teaching Schedule for Two Special Educators ).
  • Enter the courses/sections and common planning periods into the master schedule first and in a manner that avoids obvious scheduling conflicts among courses/sections at each grade level.
  • Add to the master schedule other courses/sections in which special education students will be enrolled (but that do not require in-class services from special education personnel) in a manner that minimizes conflicts with the courses/sections entered in Step 7.
  • Enter the rest of next year’s courses/classes into the master schedule.
  • Hand-schedule (by course/section/class) students with disabilities and input their schedules. If computer scheduling is employed, a decision must be made to either enter hand-scheduled course requests for students with special needs first or resolve conflicts by hand-scheduling later – that is, whether to put in extra time hand-scheduling before or after computer scheduling (Power-deFur & Orlove, 1997).
  • Administrative skill in shaping an inclusion-friendly master schedule is critical to the success of an instructional program that strives to place students with disabilities in classrooms with general education teachers proficient in delivering the SOL curriculum.

    Capper, C. Frattura, E. & Keyes, M. (2000). Meeting the needs of students of all abilities. Thousand Oaks, CA: Corwin Press.

    McLeskey, J. & Waldron, N. (2000). Inclusive schools in action. Alexandria, VA: Association for Supervision and Curriculum Development.

    Power-deFur, L. & Orlove, F. (1997). Inclusive education: Practical implementation of the least restrictive environment. Gaithersburg, MD: Aspen Publications.

    Walther-Thomas, C. Korinek, L. McLaughlin, V. L. & Williams, B. T. (2000). Collaboration for inclusive education. Boston, MA: Allyn and Bacon.

    Matrix for Identifying Students’ Direct Service Requirements/Number of Teachers/Number of Course Sections Required

    Values derived from Regulations Governing Special Education Programs for Children with Disabilities in Virginia (p. 90)

    Source:

    education.wm.edu

    Inclusive Education Laws Research Paper Starter

    Inclusive Education Laws Research Paper Starter

    Inclusive education for students with disabilities is designed to ensure that all children receive a proper education in an environment that is not restricted. The major laws governing inclusive education are the Education for All Handicapped Children Act and the Individuals with Disabilities Education Act. Since the original acts were passed, subsequent court cases have revolved around the exact definition of "least restrictive environment." Research has shown the inclusive education can improve academic achievement among disabled students, as well as foster more positive social interaction among disabled and non-disabled students. However, inclusion can deprive disabled students of specialized instruction, and, in some cases, disrupt the learning of non-disabled students.

    Keywords Continuum of Alternative Placements; Education for All Handicapped Children Act; Inclusion; Individualized Education Plan (IEP); Individuals with Disabilities Education Act (IDEA); Least Restrictive Environment; Mainstreaming; Related Services; Supplementary Aids and Services; Students with Disabilities

    Education Overview

    In 1975, Congress passed the Education for All Handicapped Children Act. The law came about, in part, after a report found that over 60% of the country's disabled students were not receiving an appropriate education, and some research indicated that millions of children constantly being excluded from school, or were not getting a proper education that could help, not hinder, their disabilities (Yell, 1998; Irmsher, 1995, as cited in McCarty, 2006). The law's intent was to make sure that students with disabilities would be taught with other children who did not have disabilities (Kluth, Villa & Thousand, 2002, as cited in McCarty, 2006). In 1991, the Education for All Handicapped Children Act was renamed the Individuals with Disabilities Education Act (Irmsher, 1995, as cited in McCarty, 2006). Along with the renaming of the act, certain learning disabilities were reclassified, and autism and traumatic brain injury were added (McCarty, 2006).

    The Individuals with Disabilities Education Act (IDEA) requires that students with disabilities be taught in the "least restrictive environment" possible with students who are not disabled (Lipton, 1994, as cited in McCarty, 2006) and that schools must take steps to ensure the comfort of children with disabilities in the regular classroom. These steps could include giving supplementary aids and changing the curriculum of the general education class (Yell, 1998). The updated Act also mandates that "various alternative placement options are required also by the regulations of the Act in order to assure that each student with disabilities receives an education which is appropriate for his/her individual need" (Wigle, Wilcox & Manges, 1994, as cited in McCarty, 2006). Another part of the act says that "special classes, separate schooling, or other removal of handicapped children from the regular education environment occur 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" (Yell, 1998; McCarty, 2006).

    The Least Restrictive Environment Mandate

    The Individuals with Disabilities Education Act requires schools to educate students with disabilities in the least restrictive environment possible, which means they should be educated as closely as possible with students who do not have disabilities. Thus, students with disabilities have a right to be educated in a regular education classroom with their peers. The second part states that students do not have to be educated in a regular classroom with their non-disabled peers if they cannot be satisfactorily educated. This means that if students with disabilities cannot receive an education in a regular classroom that meets their particular needs, they may move to a different educational setting where they can receive an appropriate education. With respect to least restrictive environments, a general education classroom is considered to be the least restrictive and any educational setting that affords students with disabilities little contact with their non-disabled classmates is considered to be more restrictive (Yell, 1998). The less an educational setting for students with disabilities mirrors a general education environment, the more restrictive the environment is considered to be (Gorn, 1997, as cited in Yell, 1998).

    A least restrictive environment is considered to be any setting that is limited in its educational restraining for the student, which allows them to grow, learn, and succeed in an educational setting. It is up to each student's individualized education program (IEP) team or a group consisting of parents, educators, and others who are involved with students with disabilities to determine what constitutes a least restrictive environment for each disabled student (McCarty, 2006).

    Interpreting the Law

    With the laws that helped establish inclusive education came court cases that specify what should be the proper implementation of inclusive education, but there is still no clear-cut language in court decisions that states how this should be done. This lack of clarity results in schools, school districts, and states interpreting the language of the law, which results in interpretations that match their particular view on inclusive education and the degree to which their students with disabilities are immersed in a regular general education classroom (McCarty, 2006). Issues and interpretations are further complicated by the fact that people both inside and outside of the education field often talk about “least restrictive environment,” “inclusion,” and “mainstreaming” as if they mean the same things when, in actuality, they cannot be used interchangeably (Douvanis & Hulsey, 2002, as cited in McCarty, 2006).

    The concept of educating students in a least restrictive environment developed in the 1970s from the Education for All Handicapped Children Act, and has since become a requirement in all schools (Bateman & Bateman, 2002). Inclusion refers to having students with disabilities in a general education classroom with non-disabled students, and “implies that students with disabilities will be taught outside a regular education classroom only when all available instructional methods have been utilized and failed to meet their needs” (Bateman & Bateman, 2002, as cited in McCarty, 2006, p. 6). Full inclusion refers to placing children with disabilities in a regular education classroom every day (McCarty, 2006). Students with disabilities in an inclusive setting still receive direct support from special educators (Hines, 2001). Inclusion is different from mainstreaming because “students are part of only the general education classroom and do not belong to any other specialized education setting based on their disability” (Halvorsen & Neary, 2001, as cited in Hines, 2001, p. 2).

    Mainstreaming is used to refer to when students with disabilities are “in a special education classroom setting for most of the day and then go into a general education classroom for parts of the school day” when the general education class is working on activities where it is believed that the disabled student will excel (McCarty, 2006, p. 6).

    The Continuum of Alternative Placements

    To make sure that schools provide a range of educational opportunities for students with disabilities with respect to differing levels of least restrictive environment, the Individuals with Disabilities Education Act requires school districts to have a continuum of alternative placements. Continuum of placements can include being taught in regular classes and schools as well as special classes and schools. Education in homes, hospitals or institutions is also included (Bateman & Bateman, 2002). The purpose of having a continuum of alternative placements is to enable the schools to select from a number of options when determining a student's placement so that they are not either completely included or completely excluded from participating with their.

    (The entire section is 3589 words.)

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    PPT - Why Inclusive Education for Heritage High #425? PowerPoint Presentation

    Why Inclusive Education for Heritage High #425. PowerPoint PPT Presentation

    Why Inclusive Education?-Research Basis

    “In general, students with disabilities in inclusive settings have shown improvement in

    standardized tests, acquired social and communication skills previously undeveloped, shown

    increased interaction with peers, achieved more and higher-quality IEP goals, and are better

    prepared for post-school experiences. There is also evidence that inclusive settings can expand

    a student's personal interests and knowledge of the world, which is excellent preparation for

    adulthood. The positive effects of inclusive education on classmates without disabilities have

    been well documented. Both research and anecdotal data have shown that typical learners

    have demonstrated a greater acceptance and valuing of individual differences, enhanced self esteem,

    a genuine capacity for friendship, and the acquisition of new skills. Low-achieving

    students also benefited from the review, practice, clarity, and feedback provided to students

    with disabilities. When inclusive education is implemented appropriately, all students

    (From Inclusive Education: Practical Implementation of the Least Restrictive Environment by Power-deFur and

    Orelove. Aspen Publishers, Inc. 200 Orchard Ridge Drive, Suite 200, Gaithersburg, MD 20878)

    Understanding the Least Restrictive Environment (LRE)
    • A- out of general education classroom <21% of the school day
  • B- out of the general education classroom 21-60% of the school day

    • C- out of the general education classroom >60% of day the school day
  • F &G- separate public and private schools

    MSDE Leadership Action Plan
    • The State Board of Education should pass a least restrictive environment policy and request regular updates from MSDE staff with regard to efforts to increase students with disabilities’ academic progress and their inclusion in the general education classroom.
  • The State Superintendent should use the superintendent’s position to emphasize the overwhelming body of research evidence supporting inclusive education, academic accountability for ALL students, and the need for system reform, and make it a focal point of MSDE’s agenda.

  • The Maryland State Department of Education, in its oversight role, should require that all local school systems develop and implement LRE improvement plans as part of local school system comprehensive master plans.

  • MSDE should provide incentives for schools to increase the academic performance of students with disabilities and their rates of inclusion.

  • Local Boards of Education should review their data on the educational performance and placement of students with disabilities, disaggregated by disability label, age, and race, and develop improvement plans accordingly.

    MSDE Accountability Action Plan
    • MSDE should set and enforce standards for the inclusion of students with disabilities in the general education classroom, just as there are standards for educating general education students.
  • MSDE should align its discretionary funds with system needs that have been identified through Focused Monitoring. Discretionary grants should be used to build the capacity of public schools to serve students with disabilities in the least restrictive environment.

  • MSDE should ensure that each local special education department makes public its annual staffing plan and provides opportunity for feedback from parents and the community before submitting the finalized plan to the local school board for approval as required by COMAR 13A.05.02.13 [D].

  • MSDE should review local special education staffing plans for bias towards placement of students in restrictive placements. When bias or other problems are found, MSDE, through the provision of technical assistance and enforcement, should ensure revision of the plans so that students with disabilities will receive appropriate special education services in the least restrictive environment in which their needs can be met.

    Parental Opinions

    Research shows that parents whose children with disabilities are placed in segregated settings express doubts about the benefits of inclusive education; however, parents who have experienced quality inclusive education are overwhelmingly supportive of inclusion.

    Parents are more likely to advocate for inclusive elementary and secondary school placements if their child has been included with typical peers during the preschool years.

    Parents cannot meaningfully advocate for inclusion without knowing what it is or having a sense of what effective inclusion looks like.

    Begin inclusion early by educating young children with disabilities in natural environments.

    Provide incentive grants to local school systems to develop training in inclusive education for parents and educators.

    Identify model inclusive schools in each local school system and provide parents with opportunities to observe inclusive classrooms that include children with all levels and types of disabilities.

    Implement capacity-building efforts so that neighborhood schools and public school systems can become a real choice for parents.

    Goal for Heritage High Inclusive School

    #425 Inclusive school:

  • provide access to knowledge, skills, and information to all students,

  • tailor learning to meet individual needs,

  • encourage co-teaching and collaboration among general and special educators,

  • collaborate with families and community members,

  • think outside the box in terms of school structure and finance,

  • maintain high expectations of all students,

  • engage in continuous improvement, and

  • promote and support inclusive communities.

    #425 Inclusive Practices Science & Social Studies Action Plan
    • Effective 01/03/12 Self-Contained Science and Social Studies Classes will no longer exist at #425
  • General and Special Educators will being the Co-Teaching process as it pertains to those courses.

  • City Schools will assist with training and professional development to ensure the successful implementation of Co-Teaching.

  • All stakeholders will assist with the transition of the inclusion model and assist students collaboratively.

    6 Key Shifts for #425 Teachers
    • 1. From how do I teach to how do my students LEARN
  • 2. From what services will I provide to what SUPPORTS do my students need

  • 3. From the “lone arranger” of the classroom to GROUP PRACTICE

    • 4. From disciplining behavior to facilitating the development of PROSOCIAL classroom environments through teaching and encouraging the development of knowledge, skills, and responsibility for the common good
  • 5. From reform to CONTINOUS, DATA DRIVEN, IMPROVEMENT and RENEWAL

    6 Key Shifts for #425 Teachers
    • 6. From parent involvement to PARTNERSHIP with families and communities schools differ because the assets of their staffs and their leadership differ. The mix of novice and experienced teachers, their own socio‐cultural histories, their educational backgrounds both personal and professional, and the leadership and mentoring provided with a school create different contexts and experiences.

    Importance of Inclusion
    • Education is a priceless gift. We can’t afford to leave out the important piece of citizenship. Our children are the future with all their strengths and weaknesses, and we need to make sure they have the opportunity to live and work together throughout their lives.

    Source:

    www.slideserve.com

  • Least Restrictive Environment, Mainstreaming, and Inclusion

    Least Restrictive Environment, Mainstreaming, and Inclusion

    Collect This Article

    The terms least restrictive environment, inclusion, and mainstreaming are often used interchangeably. They are not, however, synonymous concepts. Least restrictive environment refers to the IDEA’s mandate that students with disabilities should be educated to the maximum extent appropriate with peers without disabilities. The LRE mandate ensures that schools educate students with disabilities in integrated settings, alongside students with and without disabilities, to the maximum extent appropriate. Least restrictive environment is not a particular setting.

    Champagne (1993) defines restrictiveness as “a gauge of the degree of opportunity a person has for proximity to, and communication with, the ordinary flow of persons in our society” (p. 5). In special education, this means that a student with disabilities has the right to be educated with students in the general education environment. The general education environment is considered the least restrictive setting because it is the placement in which there is the greatest measure of opportunity for proximity and communication with the “ordinary flow” of students in schools.

    From this perspective, the less a placement resembles the general education environment, the more restrictive it is considered (Gorn, 1996). Specifically a student with disabilities has the right to be educated in a setting that is not overly restrictive considering what is appropriate for that student. Appropriateness entails an education that will provide meaningful benefit for a student. When the educational program is appropriate, a student with disabilities should be placed in the general education environment, or as close to it as is feasible, so long as the appropriate program can be provided in that setting.

    Inclusion refers to placement of students with disabilities in the general education classroom with peers without disabilities. Inclusion generally connotes more comprehensive programming than the somewhat dated term mainstreaming. The courts, however, tend to use the terms synonymously. Mainstreaming and inclusion are narrower terms than least restrictive environment (McColl, 1992). Although placement in the general education classroom may be the LRE for some students with disabilities, it is not required in all cases. The IDEA requires mainstreaming or inclusion when the general education classroom setting can provide an appropriate education. This view was also expressed by the U.S. Court of Appeals for the Fourth Circuit in Carter v. Florence County School District Four (1991):

    Under the IDEA, mainstreaming is a policy to be pursued so long as it is consistent with the Act’s primary goal of providing disabled students with an appropriate education. Where necessary for educational reasons, mainstreaming assumes a subordinate role in formulating an educational program. (p. 156)

    The LRE Mandate

    The IDEA requires that, when appropriate, students with disabilities be educated in settings with children without disabilities. Specifically the law provides that,

    to the maximum extent appropriate, children with disabilities, including children in public or private institutions or other care facilities, are educated with children who are not disabled, and that special classes, 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. (IDEA, 20 U.S.C. § 1412)

    There are two parts to the LRE requirement of the IDEA. The first addresses the presumptive right of all students with disabilities to be educated with students without disabilities. Schools must make good faith efforts to place and maintain students in less restrictive settings. This presumptive right, however, is rebuttable; that is, the principle sets forth a general rule of conduct (i.e. integration) but allows it to be rebutted when integration is not appropriate for a student (Turnbull & Turnbull, 2002). The IDEA favors integration, but recognizes that for some students more restrictive or segregated settings may be appropriate. Clearly, the law anticipates that placements in more restrictive settings may sometimes be necessary to provide an appropriate education.

    To ensure that schools make good faith efforts to educate students in less restrictive settings, the LRE mandate also requires that before students with disabilities are placed in more restrictive settings, efforts must first be made to maintain a student in less restrictive settings with the use of supplementary aids and services. It is only when an appropriate education cannot be provided, even with supplementary aids and services, that students with disabilities may be placed in more restrictive settings.

    The IDEA further requires that state educational agencies ensure that the LRE requirement extends to students in public schools, private schools, and other care facilities. States are required to ensure that teachers and administrators in all public schools are fully informed about the requirements of the LRE provision and are provided with the technical assistance and training necessary to assist them in this effort.

    Continuum of Alternative Placements

    Senator Stafford (1978), an original sponsor of the IDEA, stated that Congress included the LRE principle in the law in recognition that for some students an education in the general education classroom would not be appropriate. For these students, placements in more restrictive settings would be required to provide an appropriate education. The U.S. Supreme Court, in Board of Education of the Hendrick Hudson School District v. Rowley (1982), interpreted congressional intent similarly:

    Despite this preference for “mainstreaming” handicapped children—educating them with nonhandicapped children—Congress recognized that regular education simply would not be a suitable setting for the education of many handicapped children. the act thus provides for the education of some handicapped children in separate classes or institutional settings. (p. 192)

    The Office of Special Education and Rehabilitation Services (OSERS) of the U.S. Department of Education also recognized “that some children with disabilities may require placement in settings other than the general education classroom in order to be provided with an education designed to address their unique needs” (Letter to Goodling, 1991, p. 214).

    To ensure that students with disabilities are educated in the LRE that is most appropriate for their individual needs, the IDEA requires that school districts have a range or continuum of alternative placement options to meet their needs. The continuum represents an entire spectrum of placements where a student’s special education program can be implemented (Bartlett, 1993; Gorn, 1996). Regulations require that

    1. Each [school district] shall ensure that a continuum of alternative placements is available to meet the needs of children with disabilities for special education and related services
    2. The continuum required. must:
      • Include the alternative placements. (instruction in regular classes, special classes, special schools, home instruction, and instruction in hospitals and institutions); and
      • Make provision for supplementary services (such as resource room or itinerant instruction) to be provided in conjunction with regular class placement. (IDEA Regulations, 34 C.F.R. § 300.551)

    The purpose of the continuum is to allow school personnel to choose from a number of options in determining the LRE most appropriate for the student. OSERS has emphasized the importance of school districts’ maintaining a continuum of placements “in order to be properly prepared to address the individual needs of all children with disabilities” (Letter to Frost, 1991, p. 594). If the local school district is unable to provide the appropriate placement, the state may bear the responsibility of ensuring the establishment and availability of a continuum of alternative placements (Cordero v. Pennsylvania, 1993).

    A school district may not refuse to place a child in an LRE because it lacks the appropriate placement option (Tucker & Goldstein, 1992). Moreover, if gaps in the continuum exist within a school district, the district must fill them through whatever means are required (e.g. consortium-type arrangements). This does not mean that each school district must provide for a complete continuum within its own boundaries. When the educational needs of a student cannot be met in district programs, however, the district is obligated to provide a placement where the student’s needs can be met. The regulations implementing the IDEA require that the various alternative placements in the continuum of placements “are to be available to the extent necessary to implement the individualized education program” (IDEA Regulations, 34 C.F.R. § 300.552(b)). This may necessitate the district’s sending the student to another school (public or private) that provides the needed placement. In such cases, the neighborhood school district retains financial responsibility for the student’s education.

    The IEP team determines the placement along this continuum that is the least restrictive setting in which a student will receive an appropriate education. Restrictiveness is defined, for purposes of the continuum, by proximity to the general education classroom. Education in the least restrictive setting (i.e. the general education classroom) is the preferred option so long as it is consistent with an appropriate education. If a student cannot receive a meaningful education in the general education classroom, another placement, in which the student will receive a meaningful education, is required.

    Source:

    www.education.com

    Least Restrictive Environment

    Least Restrictive Environment

    One of the key mandates of the Individuals with Disabilities Education Act (IDEA) is that all students with disabilities are to be educated in the least restrictive environment (LRE). This requirement applies across the continuum of placement alternatives that a school board needs to maintain under the statute.

    In particular, the IDEA requires states, and consequently school boards, to set up procedures ensuring that students with disabilities are educated to the maximum extent appropriate with children who do not have disabilities. The IDEA further directs that students with disabilities be placed in special classes or separate facilities, or otherwise be removed from the general education environment only when the nature or severity of their disabilities is such that instruction in general education classes cannot be achieved satisfactorily, even with supplementary aids and services. The IDEA’s LRE provisions relate to students who attend private schools, institutions, or other care facilities at public expense in addition to those who attend special education programs within the public schools. The IDEA’s LRE provisions are so intertwined with the statute’s requirement to provide a free appropriate public education that one is rarely mentioned without reference to the other.

    Required Inclusion

    In Board of Education of the Hendrick Hudson Central School District v. Rowley (1982), the U.S. Supreme Court stated that an appropriate education is one that is formulated pursuant to all of the IDEA’s procedures and is sufficient to confer some educational benefit on a student with disabilities. The Court added that the program provided to a student in a special education placement who attends school in a regular classroom setting should enable the child to achieve passing marks and advance from one grade to the next.

    In determining the least restrictive setting for a given student, school officials need to consider a variety of factors, including the student’s educational needs and social needs. Initial guidance in this regard was provided by several high-profile court cases. In two of these cases, federal appellate courts directed school boards to place students with disabilities in regular settings, as opposed to segregated special education classrooms. In both disputes, the courts insisted that educators must consider a variety of factors when formulating the LRE for children with disabilities.

    In a case from New Jersey, Oberti v. Board of Education of the Borough of Clementon School District (1993), the Third Circuit adopted a two-part test, originally outlined by the Fifth Circuit in litigation from Texas (Daniel R. R. v. State Board of Education, 1989), for evaluating compliance with the IDEA’s LRE mandate. The first component of the test asks whether the child in question can be educated satisfactorily in a regular classroom with the use of supplementary aids and services. The second element of the test, which is applicable when a placement outside of the general education setting is necessary, asks whether the child will be placed to the maximum extent appropriate with children who are not disabled.

    The Ninth Circuit in Sacramento City Unified School District Board of Education v. Rachel H. (1994), a dispute from California, summarized the pronouncements of several courts when it stated that school officials must consider four factors in making LRE placements: the educational benefits of placing children with disabilities in regular classrooms, the nonacademic benefits of such placements, the effect that the presence of students with disabilities would have on teachers and other children in a class, and the costs of inclusionary placements. Each of these factors must be taken into account when placing students with disabilities in any educational program.

    Approved Exceptions

    Included in both the Oberti and Rachel H. opinions is the principle that school authorities must make reasonable efforts to place students with disabilities in inclusive settings by providing them with supplementary aids and services to ensure their success prior to considering more restrictive placements. Despite the emphasis on inclusion. not all students with disabilities are best placed in general education classes. Due to the nature or severity of their disabilities, many students are better served in more restrictive settings. Courts will approve segregated settings over parental objections when individualized educational (IEP) teams can show that students with disabilities cannot function in regular classrooms or will not receive educational benefit in such settings, even with the addition of supplementary aids and services (Beth B. v. Van Clay, 2002; Clyde K. v. Puyallup School District No. 3, 1994; Capistrano Unified School District v. Wartenberg, 1995). In one such situation, the federal trial court in New Hampshire recognized that an IEP calling for inclusion in some subjects was not suitable for a 15-year-old student who was reading on a first-grade level (Manchester School District v. Christopher B. 1992).

    In essence, a placement in the general education setting should be the placement of choice, and a segregated setting should be considered only if a fully inclusive placement has failed despite the best efforts of educators or there is overwhelming evidence that it is not reasonable.

    Allan G. Osborne, Jr.

    • Beth B. v. Van Clay, 282 F.3d 493 (7th Cir. 2002).
    • Board of Education of the Hendrick Hudson Central School District v. Rowley. 458 U.S. 176 (1982).
    • Capistrano Unified School District v. Wartenberg, 59 F.3d 884 (9th Cir. 1995).
    • Clyde K. v. Puyallup School District No. 3, 35 F.3d 1396 (9th Cir. 1994).
    • Daniel R. R. v. State Board of Education, 874 F.2d 1036 (5th Cir. 1989).
    • Individuals with Disabilities Education Act, 20 U.S.C. §§ 1400 et seq.
    • Manchester School District v. Christopher B. 807 F. Supp. 860, (D.N.H. 1992).
    • Oberti v. Board of Education of the Borough of Clementon School District, 995 F.2d 1204 (3d Cir. 1993).
    • Sacramento City Unified School District Board of Education v. Rachel H. 14 F.3d 1398 (9th Cir. 1994), cert. denied, 512 U.S. 1207 (1994).

    Source:

    usedulaw.com

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