It’s instruction over place — not the other way around!




Advocates of inclusion, with their emphasis on the place of instruction as opposed to instruction itself, are putting the cart before the horse, according to the logic of the law.


Suppose that every Olympic event had to be held in the same environment. No special environments for swimming, running, or soccer; no special grassy field or track marked with lanes. Sports are sports, the thinking goes, so to be fair, all competitions should be held in a single arena or stadium. Not only that, but all athletes are just that — athletes. So for swimming, say, there should be no competition just for the butterfly or the breast stroke; all swimmers should swim all strokes and distances.

Or suppose in hospitals there were no ICUs, no NICUs, or no maternity wards, none of that “special” stuff, just good hospital care for everyone because, after all, hospitals are hospitals, doctors are doctors, and patients are patients.

It wouldn’t take you long to think these are really crackbrained ideas. Yet we let similar nonsense pass for innovation in education.

Many recent proposals to reform or transform general and special education have emphasized full inclusion — that is, moving all students with disabilities into regular or general education. The idea is that all schools and classes should serve all students so that no students are taught in special, dedicated environments (Brigham, Ahn, Stride, & McKenna, 2016; Gliona, Gonzales, & Jacobson, 2005; Kauffman et al., 2016; Kauffman, Ward, & Badar, 2016). For instance, take California’s state plan for inclusion (The Special Edge, 2016). There, the place of instruction is what matters most; the assumption is that all instruction can and should be offered in the same place.

The idea of having all students together in the same schools and classes regardless of their needs for special instruction is taken seriously or even mandated by various legislators and  administrators. But the fact is, this can make teachers’ jobs impossible and place undue stress on both teachers and their students.

Double ironies

Movement toward full inclusion reveals two remarkable ironies, one legal and one conceptual. The legal irony is that the U.S. Department of Education supports projects such as SWIFT (School-Wide Integrated Framework for Transformation) at the University of Kansas; the project’s motto is “All means all” ( However, federal law requires a continuum of alternative placements, not full inclusion (see Bateman, 2007, in press; Martin, 2013; Yell, 2016; Yell, Crockett, Shriner, & Rozalski, in press). In fact, in spring 2016, a federal appeals court found that the Los Angeles Unified School District’s abandonment of a continuum of alternative placements in favor of inclusion violated the federal law, the Individuals with Disabilities Education Act (IDEA) (Smith v. LAUSD, 2016). So the legal irony is that the U.S. Department of Education supports full inclusion projects that are illegal under its own law.

The conceptual irony is that although some have suggested that special education be reconceptualized as a service, not a place, special education never was conceptualized as a place to begin with. Blackman (1992) epitomized the growing emphasis on place almost a quarter of a century ago:

“Place” is the issue . . .  There is nothing pervasively wrong with special education. What is being questioned is not the interventions and knowledge that has (sic) been acquired through special education training and research. Rather, what is being challenged is the location where these supports are being provided to students with disabilities (p. 29).

The place of instruction, not instruction itself, has become the central focus of the full inclusion movement. It’s been made the focus by the very people who say it shouldn’t be.

The illogic of full inclusion

Attempts to transform general and special education to conform to the full inclusion ideal are not only illegal — they’re also illogical. The idea that instruction can be improved simply by changing where it’s delivered or that all instruction can best be delivered in a general education context is inconsistent with experience and careful thinking. We know that teaching environments that are relatively free of distraction are better than those with frequent distractions. We know that environments that are relatively free of stress are better than those in which stress is high. We know that learning is more likely when both student and teacher know that the student can accomplish the required tasks.

One common reason given for adopting full inclusion is that students with disabilities will be exposed to challenging standards and a rich general education curriculum. However, expectations that are higher than an individual can reach can be humiliating to that person. Good instructors realize that expectations can be beyond the reach of a given individual at a given time and that expectations far beyond a student’s ability may be counterproductive. Further, the notion that exposure to a curriculum grants access to it is not founded in logic or reality (Fuchs et al., 2015). Logic demands that some special education needs require special curriculums.

Moreover, full inclusion raises the demand for accommodation or differentiation to unreachable heights for most teachers. “Ought implies can” was an ethical principle described by philosopher Immanuel Kant; that is, before we can suggest that someone ought to do something, we first have to know whether he or she can.

Most teachers cannot do what proponents of full inclusion assume they ought to be able to do. A few highly gifted teachers who expend extraordinary time and effort may be able to teach an extraordinarily learning-diverse group of children and do it well, but most teachers cannot and should not be expected to. Those demanding full inclusion ignore both the diversity of students’ needs and the diversity of teachers’ abilities.

Another reason given for pushing the idea of full inclusion is that children with and without disabilities will socialize and learn from and about one another and that those with disabilities will see appropriate role models of behavior and learning. But concern for social benefits must not come at the expense of appropriate instruction. Many parents of children with disabilities are probably more concerned that their children learn important academic and self-care skills than learn to socialize with those who don’t have disabilities. And just because a student with disabilities doesn’t socialize at school with students without disabilities doesn’t mean that he or she has no appropriate role models. The idea that children with disabilities can’t be appropriate models reveals the bias of those using this reason to promote full inclusion. Children in special schools and classes can have an active, meaningful social life; socialization can occur during noninstructional time, such as lunch, or in extracurricular or community-based activities.

Full inclusion is blatantly illegal under IDEA, regardless of the promulgation of inclusion by state or local administrators, university faculty, or federally funded projects (see Bateman, 2007; Bateman & Linden, 2006; Bateman, Lloyd, & Tankersley, 2015; Smith v. LAUSD, 2016; Yell, 2016). The first demand of IDEA is free, appropriate public education. The first requirement is not for a least restrictive environment (Bateman & Linden, 2012; Brigham et al., 2016). The same logic of the law has existed since IDEA was first passed in 1975 — that “special education” means individualized special instruction and related services to be delivered in the most normal environment possible (Martin, 2013). The law did not envision special education as a single kind of place, and the assumption was — and is — that “least restrictive environment” must be determined after “free, appropriate public education,” and not before (see Bateman & Linden, 2014; Brigham et al., in press; Kauffman et al., in press). The logical sequence — the one that puts the horse before the cart and not the other way around — is getting instruction right, then deciding where it’s best offered.

Instruction first

We’re not opposed to all inclusion, only to the irresponsible ideas that (a) all individuals with disabilities should be included in general education, and (b) inclusion is the first or most important consideration. The “all means all” mantra and its demand of no exceptions imply that the place of instruction comes first and that appropriate instruction can always be delivered in general education. This is nonsense. Good, responsible thinkers and educators have described the major features of instruction in special education (see Pullen & Hallahan, 2015). Individualized instruction in special education is varied in explicitness, intensity, pace, size of the group being taught, duration and frequency of instruction in specific skills, immediacy of corrective feedback, and reinforcement appropriate for the individual and task. Instruction individualized along these dimensions simply cannot be done well for all students in a single environment.

Responsible inclusion means placing students with disabilities in general education when — and only when — that’s where they’ll receive the most effective instruction in the skills most important to their futures. Feelings of belonging, acceptance, and dignity are important, but these aren’t available only to those taught in general education. In some nations, inclusion refers to including students in public education, even if this means placing some in environments not intended to meet the needs of more typical individuals.

Responsible inclusion requires meaningful, appropriate instruction of the individual; it doesn’t require that all students must be taught under the same roof or in the same class (Bateman et al., 2015; Warnock, 2005). It means that the nature of the instruction students receive is far more important than the place where they receive it.


Bateman, B.D. (2007). Law and the conceptual foundations of special education practice. In J.B. Crockett, M.M. Gerber, & T.J. Landrum (Eds.), Achieving the radical reform of special education: Essays in honor of James M. Kauffman (pp. 95-114). Mahwah, NJ: Lawrence Erlbaum Associates.

Bateman, B.D. (in press). Individual education programs for children with disabilities. In J.M. Kauffman, D.P. Hallahan, & P.C. Pullen (Eds.), Handbook of special education (2nd ed.). New York, NY: Routledge.

Bateman, B.D. & Linden, M.A. (2006). Better IEPs: How to develop legally correct and educationally useful programs (5th ed.). Verona, WI: Attainment.

Bateman, B.D., Lloyd, J.W., & Tankersley, M. (Eds.). (2015). Enduring issues in special education: Personal perspectives. New York, NY: Routledge.

Blackman, H.P. (1992). Surmounting the disability of isolation.  School Administrator, 49 (2), 28-29.

Brigham, F.J., Ahn, S.Y., Stride, A.N., & McKenna, J.W. (2016). FAPE accompli: Misapplication of the principles of inclusion and students with EBD. In J.P. Bakken & F.E. Obiakor (Eds.), Advances in special education, Vol. 31: General and special education in an age of change: Impact on students with disabilities  (pp. 31-47). Bingley, UK: Emerald.

Fuchs, L.S., Fuchs, D., Compton, D.L., Wehby, J., Schumacher, R.F., Gersten, R., & Jordan, N.C. (2015). Inclusion versus specialized intervention for very-low-performing students: What does access mean in an era of academic challenge? Exceptional Children, 81 (2), 134-157.

Gliona, M.F., Gonzales, A.K., & Jacobson, E.S. (2005). Dedicated, not segregated: Suggested changes in thinking about instructional environments and in the language of special education. In J.M. Kauffman & D.P. Hallahan (Eds.), The illusion of full inclusion: A comprehensive critique of a current special education bandwagon (2nd ed.) (pp. 135–146). Austin, TX: Pro-Ed.

Kauffman, J.M., Anastasiou, D., Badar, J., Travers, T.C., & Wiley, A.L. (2016). Inclusive education moving forward. In J.P. Bakken & F.E. Obiakor (Eds.), Advances in special education, Vol. 32: General and special education in an age of change: Roles of professionals involved (pp. 153-177). Bingley, UK: Emerald.

Kauffman, J.M., Ward, D.M., & Badar, J. (2016). The delusion of full inclusion. In R.M. Foxx & J.A. Mulick (Eds.), Controversial therapies for autism and intellectual disabilities (2nd ed.) (pp. 71-86). New York, NY: Taylor & Francis.

Martin, E.W. (2013). Breakthrough: Federal special education legislation 1965-1981. Sarasota, FL: Bardolf.

Pullen, P.C. & Hallahan, D.P. (2015). What is special education instruction? In B.D. Bateman, J.W. Lloyd, & M. Tankersley (Eds.), Enduring issues in special education: Personal perspectives (pp. 37-50). New York, NY: Routledge.

Smith v. LAUSD, No. 14-55224. (9th Circuit Court of Appeals May 20, 2016).

The Special Edge. (2016, Spring). The challenge of change: Educational leadership. The Special Edge, 29 (2), 1, 6-8.

Warnock, M. (2005). Special educational needs: A new look. Impact No. 11. London, UK: Philosophy of Education Society of Great Britain.

Yell, M.L. (2016). The law and special education (4th ed.). Upper Saddle River, NJ: Pearson.

Yell, M.L, Crockett, J.B., Shriner, J., & Rozalski, M. (in press). Free appropriate public education and least restrictive environment. In J.M. Kauffman, D.P. Hallahan, & P.C. Pullen (Eds.), Handbook of special education (2nd ed.). New York, NY: Routledge.


Originally published in December 2016/January 2017 Phi Delta Kappan 98 (4), 55-59. © 2016 Phi Delta Kappa International. All rights reserved.


JAMES M. KAUFFMAN ( is professor emeritus of education at the University of Virginia, Charlottesville.
JEANMARIE BADAR was a teacher of elementary students with emotional and behavioral disorders for 25 years. She is now a personal fitness trainer for adults, including those with disabilities.


  • Joel Berg

    Your article struck a very responsive chord! I taught gifted & talented students and I could not imagine mixing them with the rest of the school indiscriminately! Teachers, with the help of guidance counselors, should determine the proper placement of students based on their capacities, abilities, interests, and psychological readiness. Tests and computers cannot do this without the expertise of the teacher. I might add that “tracking” is not the same as proper placement of individuals; it usually ignores specific talents and abilities while not considering specific deficiencies. Thank you for focusing on this!

  • Brian Abdallah

    We are In a standards-based society, where expectations are that all students will meet each standard and the school will be rated on aggregate school testing results. Thus, to follow-up upon your ideas e.g. modified curriculum,, some students incapable of meeting (some) standards, etc.) it appears necessary the there would need to be a tied testing program to allow for students to demonstrate their learning and growth. This may be attacked as inequitable and discriminatory.

    However, after 44 years in education (in 9 school districts- 19 years as a principal), I think that you make some exceptionally poignant points and I am hopeful that educators and policy makers will stop expecting everyone to be in the same place (regular education classrooms) and meet all academic and behavioral standards in the same timeframe. Policymakers (state and federal) and administrators are placing way too much stress upon students and teachers with their inclusionary requirements and expectations that teachers must ensure the academic and behavioral success of all students in the same class.

  • What Professors Kauffman and Badar fail to acknowledge is that inclusion has evolved since the 1980’s when it was originally conceptualized. In the first inclusion efforts advocates focused on social benefits from being physically present in general education classrooms alongside classmates who didn’t have disabilities. The second wave of inclusion efforts expanded from the social benefit rationale to the idea that we could take advantage of opportunities for students to master their IEP goals within general education instructional and social contexts. Contemporary inclusion efforts focus on whole school restructuring for the benefit of all students through the use of Universal Design for Learning with options for how knowledge of represented, how students engage in instruction, and how they show what they know. Because segregating places have demonstrable negative effects on students with and without disabilities, we do advocate for general education places to be welcoming to all students. In the modern inclusive classroom or school disability is viewed as a natural part of human diversity. And in those very important inclusive places instruction can be designed to accommodate all students.

    • Suggest that readers check out this paper by Jackson, Ryndak, and Wehmeyer (2008/2009). The Dynamic Relationship Between Context, Curriculum, and Student Learning: A Case for Inclusive Education as a Research-based Practice. Research and Practice for Students with Severe Disabilities, 33/4, 175-195.

  • Susan

    I am shocked to read commentary about inclusive education so full of misunderstandings about general education. Have the authors been in a general education classroom lately? Do they know about Universal Design for Learning? And about the ways in which instruction, assessment, and the environment can be differentiated? I am also shocked by the inference that students without disabilities do NOT need individualized supports, accommodations, teaching strategies and learning environments. Wonderful transformation is happening in our schools that is driven by research and our understanding of the learning needs of ALL children.

  • Linda Quintanilha

    Although I suspect your editorial piece was well intended, I would disagree with many of the thoughts presented. Not because I don’t respect the opinions offered, but they are opinions without considering history and current realities for children with disabilities in our schools.

    Full inclusion from my perspective, as a parent of a child with a significant disability and a school board member, does not abandon the continuum of alternative placements. It simply means that the goal of all administrations should be the Least Restrictive Environment, mandated by IDEA. I suspect we can all agree that on the continuum of placements and services, the Least Restrictive Environment is the general education setting.

    With shrinking budgets administrations all over the country have been designing programs for our kids. Many schools have Autism Programs, Life Skills, and others. They created these programs for the most efficient and what they believe effective way to provide services like OT, PT and Speech. As these programs are developed, students and families find themselves being presented with these placements in their IEP meetings. The general education setting is too often not offered as the Least Restrictive Environment. The practice has become, build the program, place students there, and keep budgets manageable.

    Inclusion is not illegal and to suggest otherwise is irresponsible. Stating that instruction can be improved for kids simply by changing the placement is also a misstating everything I have learned about inclusion. No inclusion advocate that I know, would ever suggest that simply changing placement without supports for teachers and the overall school community is a good idea. I can say however, that by providing opportunities for co-teaching, differentiated instruction and most importantly by giving all kids a sense of belonging is in the best interests of all students, not just those with disabilities.

    Finally, places within your piece imply children with significant disabilities are either too much work or can’t be expected to learn what other kids can learn. Given the centuries of discrimination faced by individuals with disabilities, I’m not surprised by your comments. I hear them every day. However, technology is advancing and students with even the most significant disabilities are showing us that they are capable of not just learning alongside their peers, but surpassing them academically.

    Full inclusion is not blatantly illegal, it is a goal and I applaud SWIFT and other programs helping schools reach that goal.

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