International trends in the education of students with special educational needs


International Perspectives on Inclusive Education



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13.3 International Perspectives on Inclusive Education


In a recent book outlining international perspectives on inclusive education, Mitchell (2005) and his authors explored the notion that the characterisation, purpose and form of inclusive education reflect the relationships among the social, political, economic, cultural and historical contexts that are present at any one time in a particular country and/or local authority. Among the 16 propositions to emerge from this overview, seven are particularly pertinent to the present review:

  1. Inclusive education extends beyond special needs arising from disabilities and includes consideration of other sources of disadvantage and marginalisation, such as gender, poverty, language, ethnicity, and geographic isolation. The complex inter-relationships that exist among these factors and their interactions with disability must also be a focus of attention.

  2. Inclusion goes beyond education and should involve consideration of employment, recreation, health and living conditions. It should therefore involve transformations across all government and other agencies at all levels of society.

  3. While many countries seem committed to inclusive education in their rhetoric, and even in their legislation and policies, practices often fall short. Reasons for the policy-practice gap in inclusive education are manifold and include barriers arising from societal values and beliefs; economic factors; a lack of measures to ensure compliance with policies; the dispersion of responsibility for education; conservative traditions among teachers, teacher educators and educational researchers; parental resistance; lack of skills among teachers; rigid curricula and examination systems; fragile democratic institutions; inadequate educational infrastructures, particularly in rural and remote areas; large class sizes; resistance from the special education sector (especially special schools); and a top-down introduction of inclusive education without adequate preparation of schools and communities.

  4. Inclusive education exists in historical contexts in which vestiges of older beliefs co-exist with newer beliefs.

  5. Inclusive education is embedded in a series of contexts, extending from the broad society, through the local community, the family, the school and to the classroom.

  6. Because cultural values and beliefs, levels of economic wealth, and histories mediate the concept of inclusive education, it takes on different meanings in different countries, and even within countries. The form taken by inclusive education in any particular country is influenced by the nature of the settlements reached at any one time between (a) traditional values such as social cohesion and group identity, collectivism, images of wholeness, fatalism, hierarchical ordering of society, and (b) modernisation values such as universal welfare, equity and equality, democracy, human rights, social justice, individualism, and parent choice.

  7. Economic considerations play a significant role in determining approaches to inclusive education. These include (a) a recognition that it would not be financially realistic to provide special schools throughout a country, (b) the adoption of a human capital policy of developing all individuals primarily as a means of enhancing the economy, and (c) an attitude that persons with disabilities are economic liabilities and are therefore of low priority.

The United Nations and its agency, UNESCO, have played a significant role in promoting inclusive education, as noted in Chapter One, section 1.4, in the present review. The most significant event took place in June 1994 when representatives of 92 governments and 25 international organisations met in Salamanca, Spain (UNESCO, 1994). The resulting agreement, known as the Salamanca Statement, demonstrated an international commitment to inclusive education. It included these agreements:

  • those with special educational needs must have access to regular schools which should accommodate them within a child-centred pedagogy capable of meeting these needs, and

  • regular schools with this inclusive orientation are the most effective means of combating discriminatory attitudes, creating welcoming communities, building an inclusive society and achieving an education for all; moreover, they provide an effective education for the majority of children and improve the efficiency and ultimately the cost-effectiveness of the entire education system.

The Statement called upon all governments to ‘adopt as a matter of law or policy the principle of inclusive education, enrolling all children in regular schools, unless there are compelling reasons for doing otherwise’.

More recently, in December 2006, the 61st session of the United Nations General Assembly confirmed a Convention on the Rights of Disabled Persons, which included a significant commitment to inclusive education. Article 24 is the most relevant to inclusive education. It stated, inter alia, the following:



  1. States Parties recognise the right of persons with disabilities to education. With a view to realizing this right without discrimination and on the basis of equal opportunity, States Parties shall ensure an inclusive education system at all levels, and life-long learning, directed to:

    1. The full development of the human potential and sense of dignity and self worth, and the strengthening of respect for human rights, fundamental freedoms and human diversity;

    2. The development by persons with disabilities of their personality, talents and creativity, as well as their mental and physical abilities, to their fullest potential;

    3. Enabling persons with disabilities to participate effectively in a free society.

  1. In realising this right, States Parties shall ensure that:

    1. Persons with disabilities are not excluded from the general education system on the basis of disability, and that children with disabilities are not excluded from free and compulsory primary education, or from secondary education, on the basis of disability;

    2. Persons with disabilities can access an inclusive, quality, free primary education and secondary education on an equal basis with others in the communities in which they live;

    3. Reasonable accommodation of the individual’s requirements is provided;

    4. Persons with disabilities receive the support required, within the general education system, to facilitate their effective education;

    5. Effective individualised support measures are provided in environments that maximise academic and social development, consistent with the goal of full inclusion.

As of April 2015, a total of 159 countries had signed the Convention and 153 had ratified it (including Australia and New Zealand, but, notably, not the USA). As well, 92 countries had agreed to the Optional Protocol (including Australia, but not New Zealand). Under the Convention, all States parties are obliged to submit regular reports to the Committee on the Rights of Persons with Disabilities, a body of independent experts which monitors implementation of the Convention by the States Parties on how the rights are being implemented. States must report initially within two years of accepting the Convention and thereafter every four years. The Committee examines each report and makes such suggestions and general recommendations on the report as it may consider appropriate and forwards these to the State Party concerned. The Optional Protocol gives the Committee competence to examine individual complaints with regard to alleged violations of the Convention by States parties.

It should be noted, however, that neither the Salamanca Statement nor the Convention explicitly states that all SWSEN should be educated in fully inclusive settings at all levels of the education system. Nor do they explicitly exclude such an interpretation. In other words, there is a degree of ambiguity regarding the intentions of both documents with regard to the meaning of inclusion.

With the impetus provided by the UN and UNESCO, and other influences such as those outlined in Chapter One, it is not surprising that virtually all countries have policies on inclusive education, or are in the process of developing them. To attempt to summarise them would be a major task. It is perhaps sufficient to mention some countries’ approaches in order to illustrate the developments that are occurring,

England. In this country, the 2004 document Removing barriers to achievement: The Government’s strategy for SEN (Department for Education and Skills, 2004) made a clear commitment to inclusive education by embedding inclusive practice in every school and early years setting. It cited the 1997 Green Paper, Excellence For All Children, as signaling the government’s commitment to the principle of inclusion and the need to rethink the role of special schools within that context. It also referred to The SEN and Disability Act 2001 as delivering ‘a stronger right to mainstream education, making it clear that where parents want a mainstream place for their child, everything possible should be done to provide it’ (p.25). A small, but significant, caveat to the principle of inclusion, however, can be found in the 2001 Code of Practice (Department for Education and Skills, 2001), which stated that ‘A parents’ wish to have their child with a statement educated in the mainstream should only be refused in the small minority of cases where the child’s inclusion would be incompatible with the efficient education of other children’ (p.14). A further indication of England’s commitment to inclusive education is the government’s decision to place the Index for Inclusion (Booth & Ainscow, 2002) in every school.

Australia. Several Australian states have made a commitment to inclusive education. In Western Australia, for example, the aim of the Building Inclusive Schools (BIS) strategy since it commenced in 2002 has been to raise awareness across all levels of the education system of changing societal expectations in relation to the education of students with disabilities and the legal imperatives that now impact on schools. It is described as ‘a professional learning program that promotes and supports the cultural shift of inclusive educational practices in all public schools’. (For details of the Building Inclusive Schools strategy, see the following website: http://www.det.wa.edu.au/inclusiveeducation/detcms/navigation/building-inclusive-learning-environments/building-inclusive-schools/).

Similarly, the Inclusive Education Statement 2005 in Queensland aimed to (a) foster a learning community that questions disadvantage and challenges social injustice, (b) maximise the educational and social outcomes of all students through the identification and reduction of barriers to learning, especially for those who are vulnerable to marginalisation and exclusion, and (c) ensure all students understand and value diversity so that they have the knowledge and skills for positive participation in a just, equitable and democratic global society (for details see the website: http:/education.qld.gov.au/strategic/eppr/curriculum/crppr009/)

New Zealand. New Zealand’s commitment to inclusive education is reflected in the Education Act 1989 which states, inter alia, that: ‘People who have special educational needs (whether because of disability or otherwise) have the same rights to enrol and receive education at state schools as people who do not’ (Part 8 (1)). Similarly, the Human Rights Act 1993, Clause 57, states that:

It shall be unlawful for an educational establishment, or the authority responsible for the control of an educational establishment, or any person concerned in the management of an educational establishment or in teaching at an educational establishment,—



  1. to refuse or fail to admit a person as a pupil or student; or

  2. to admit a person as a pupil or a student on less favourable terms and conditions than would otherwise be made available; or

  3. to deny or restrict access to any benefits or services provided by the establishment; or

  4. to exclude a person as a pupil or a student or subject him or her to any other detriment,—

by reason of any of the prohibited grounds of discrimination [which includes disability].

As noted in Chapter Ten, the New Zealand Curriculum has inclusion as one of its eight guiding principles, with a focus on removing barriers to presence, participation, and achievement. It states that The curriculum is non-sexist, non-racist, and non-discriminatory; it ensures that [all] students’ identities, languages, abilities, and talents are recognised and affirmed and that their learning needs are addressed (p.9).

So, what progress has New Zealand made in implementing inclusive education?

According to 2014 data on school enrolments, of the students making up the 1% categorised as having high needs, only 33.5% of them were being educated in special schools. The remaining 66.5% were placed in regular schools in special classes or regular classes (no statistics were available to show this distribution).

In 2010, the Education Review Office (ERO) (2010) evaluated a sample of 199 primary and 30 secondary schools in 2010, to ascertain the extent to which they were inclusive of the 3% of ‘students with high needs’. These are ‘students with ‘significant physical, sensory, neurological, psychiatric, behavioural or intellectual impairment’ (p.3), who receive funding and support through a variety of mechanisms, such as the Ongoing and Reviewable Resourcing Schemes. (See section 13.5, below for a description of the instrument employed by ERO). Approximately 50% of the surveyed schools demonstrated inclusive practices, another 30% had ‘pockets of inclusion’ and the remaining 20% had few inclusive practices. Subsequently, the Government developed a policy, Success for All - Every School, Every Child, to promote the achievement, participation, and presence of children with special education needs in every mainstream school (Ministry of Education, 2010). In a 2014 follow-up in 152 schools, ERO found that 75% were mostly inclusive. ERO found that the most inclusive schools operated under three key principles:


  • having ethical standards and leadership that built the culture of an inclusive school;

  • having well-organised systems, effective teamwork and constructive relationships that identified and supported the inclusion of students with high needs; and

  • using innovative and flexible practices that managed the complex and unique challenges related to including students with high needs. (p.1)

  • School staff identified several benefits to inclusive education, including:

  • the positive influence of students with high needs on the culture of the school;

  • the benefit to teachers in having to adapt the curriculum to meet the diverse needs of students;

  • teachers developing networks with outside agencies and families;

  • other students having leadership responsibilities for some students with high needs.(p.27)

Among ERO’s recommendations was that the Ministry of Education should ‘build school-wide capability to build effective teaching for all students by extending effective evidence-based whole-of-school professional development programmes’ (p.2).

Apropos of the chapter on funding in the present review, it is noteworthy that ERO found that The quality of leadership, and the extent to which schools could adopt a specialised pedagogy for students with high needs, were more important than funding.’ (p.32)



Europe. In 2009, the European Agency for Special Needs Education published a set of ‘Indicators for Inclusive Education’, with the aim of developing ‘a methodology that would lead to a set of indicators suitable for national level monitoring, but that could also be applied at the European level’. The indicators were expected to have ‘a clear focus on the policy conditions that may support or hinder the development of inclusive education within schools’. (see http://www.european-agency.org/agency-projects/indicators-for-inclusive-education).

In 2014, the European Agency for Special Needs and Inclusive Education (formerly the European Agency for Development in Special Needs Education) highlighted five key messages regarding inclusive education, with proposals for actions:



  • As early as possible: all children have the right to receive the required support as soon as possible and whenever it is needed. This implies co-ordination and co-operation among services, led by one of the services concerned. The stakeholders involved need to build real communication among themselves, being able to understand and provide information to each other. Parents are key stakeholders.

  • Inclusive education benefits all: inclusive education aims to provide quality education for all learners. In order to achieve an inclusive school, support is needed from the entire community: from decision-makers to end-users (learners and their families). Collaboration is required at all levels and all stakeholders need a vision of long-term outcomes – the type of young people the school and the community will ‘produce’. Changes in terminology, attitudes and values, reflecting the added value of diversity and equal participation, are needed.

  • Highly qualified professionals: in order for teachers and other education professionals to be prepared for inclusion, changes are needed in all training aspects – training programmes, daily practices, recruitment, finances, etc. The next generation of teachers and education professionals must be prepared to be teachers/trainers for all learners; they need to be trained not just in terms of competences but also of ethical values.

  • Support systems and funding mechanisms: the best indicators for financing are not to be found in finances, but in measuring efficiency and achievement. It is essential to consider outcomes and relate them to the efforts invested to achieve them. This involves monitoring and measuring the systems’ efficiency in order to focus financial means towards successful approaches. Incentive structures should ensure that more financial support is available if learners are placed in inclusive settings, and that greater emphasis is placed on outcomes (not just academic ones).

  • Reliable data: meaningful, quality data collection requires a systemic approach encompassing learner, placement, teacher and resourcing issues. Data related to learner placement is a useful and necessary starting point, but it needs to be supplemented with clear data on system outcomes and effects. Data on learner outcomes – the impact of inclusive education – is much harder to collect and is often lacking in countries’ data collection.

Earlier, the Council of the European Union (2010 had stressed the importance of ensuring that learners with disabilities not only participated fully in the learning process in mainstream schools, but that they were able to achieve.

USA. The United States has a voluminous literature and a range of policies relating to inclusive education, although the term is not employed in official documents. A recent reflection by Sailor (2009) sums up the present status of inclusive education:

Without question, one of the thorniest policy questions to confront American education in the second half of the twentieth century and continuing today is the issue of placement for students served under the Individuals with Disabilities Education Act (IDEA). Federal policy consistently has used the least restrictive environment (LRE) language in statutory and regulatory policy to enhance the integration of students with disabilities and greater access to the curriculum of general education. In addition, families assisted by advocacy organizations have litigated successfully to achieve these ends for their children with disabilities. Some of these cases have produced favourable interpretations at the level of the Supreme Court. Finally, university researchers associated with special education departments around the country built a strong case for more positive educational and social outcomes for children when they are educated alongside their nondisabled peers. Despite this three-pronged effort, educational segregation of students with disabilities continues on a large scale today (p.467).


Sailor’s final point is reflected in Table 17.3 in Chapter Seventeen, which shows that in 1995, only 26.2% of students with disabilities were receiving their education in regular classroom settings.


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