1. LRE, Mainstreaming, and Inclusion
Martin E. Block, Ph.D.
Curry School of Education
University of Virginia 1

2. Definitions Least Restrictive Environment Mainstreaming
Regular Education Initiative
Inclusion 2

3. Least Restrictive Environment
LRE defined in federal law:
To the maximum extent appropriate, children with disabilities...are educated with children without disabilities, and that special classes, separate schooling, or other removal of children with disabilities from regular education environments 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.” (Federal Register, August, 1977, p ). 3

4. Mainstreaming
Process of placing eligible children into regular education classes with appropriate services determined by the IEP.
providing most appropriate education in LRE
placement based an assessed educational needs
provide support to general educators
uniting general and special education
(CEC definition of mainstreaming in 1975) 4

5. Regular Education Initiative
Consolidate the dual system of special and regular education to serve students with mild disabilities more effectively in regular education (Will, 1986).
increased instructional time
empowerment of principals to control all programs and resources at the building level
provision of support systems for regular ed. teachers
use of new approaches such as curriculum based assessment, cooperative learning, and personalized curricula (Will, 1986). 5

6. Perceived Problems with LRE (Taylor, 1988)
LRE legitimizes restrictive environments.
LRE confuses segregation and integration on the one hand with intensity of services on the other.
LRE is based on a readiness model
LRE supports primacy of professional decision making
LRE direct attention to physical setting rather than services 6

7. Inclusion Placement in home school.
Basing these students in age-appropriate, regular education classrooms.
Using the principle of natural proportions.
Providing supplementary aids and services.
Viewing special education (and APE) as a service, not a placement. 7

8. Inclusion (continued)
Supplementary Aids
Special equipment
Special instruction
Special peer groupings
Personnel (e.g., peer tutors, teacher assistants)
Individualized programs 8

9. Inclusion (continued)
Individualized Programming
Long term, top down planning
Instruction in prioritized curricular content
Individually determined instruction 9

10. Least Restrictive Environment
LRE defined in federal law:
To the maximum extent appropriate, children with disabilities...are educated with children without disabilities, and that special classes, separate schooling, or other removal of children with disabilities from regular education environments 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.” (Federal Register, August, 1977, p ). 10

11. Continuum of LRE Options
“...a continuum of alternative placements is available to meet the needs of children with disabilities... including instruction in regular classes, special classes, special schools, home instruction, and instruction in hospitals.” (Federal Register, 1977).
Placement will be different for each child.
Placement should be in most “normal” environment in which child can succeed.
Placement should not be based on a label. 11

12. Physical Education Placement Options
Regular physical education - no support
Regular physical education - consult from APE
APE conducted within regular physical education
Part-time regular physical education; part-time elsewhere (flexible schedule)
Part-time regular physical education; part-time elsewhere (fixed schedule)
Full-time separate program in regular school
Full-time separate program in special school 12

13. Placement Decisions Placement will be different for each child.
Placement should be in most “normal” environment in which child can succeed.
Placement should not be based on a label. 13

14. Court Cases Related to LRE
Roncker (OH, 1983)
Daniel (TX, 1989)
Greer (GA, 1991)
Oberti (NJ, 1993)
Holland (CA, 1994)
Klinton (TX, 1993) 14

15. Roncker v. Walters (Ohio) 1983
Case Law
Principal of Portability
What makes special placement so special?
Can this “specialness” be brought to regular class?
Benefits to child?
Disruptions? 15

16. Daniel R. R. v. State Board of Education (Texas) 1989 “Daniel R. R
Daniel R.R. v. State Board of Education (Texas) “Daniel R.R. Test”
Can education in regular classroom, with supports, be achieved satisfactorily?
If it cannot, has the school “mainstreamed” the child to the maximum extent appropriate? 16

17. Daniel R.R. (Cont.)
Can Education in Regular Class, with Support, be Achieved?
Did school system take steps to include student?
Will student receive any educational benefit?
Were there any negative effects on other children? 17

18. Other Important Court Cases
Greer v. Rome (GA) City School District (1991)
Predetermination?
Non-academic benefit?
Financial burden?
Oberti v. Borough of Clementon (NJ) School District (1993)
Burden of proof?
Supplementary aids?
Modifying curriculum? 18

19. Other Important Court Cases (cont.)
Sacramento (CA) City Unified School District v. R. Holland (1994).
Educational benefit (same?)
Non-academic benefit
Effects on teacher and other children
Cost of supplementary aids
Klinton v. Corpus Christi (TX) ISD (1993)
Behavior problems 19