Least Restrictive Environment, Mainstreaming, and Inclusion

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.

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.

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5 Benefits of Inclusion Classrooms

If your child is eligible for special education services, you may worry he’ll be placed in a different classroom than other kids his age. But most kids might be place in classrooms that are known as inclusion (or inclusive) classrooms.

In an inclusion classroom, the general and special education teachers work together to meet your child’s needs.

This is key. As Carl A. Cohn, Ed.D., executive director of the California Collaborative for Educational Excellence, points out, “It’s important for parents to realize that special education students are first and foremost general education students.”

Many schools have inclusion classrooms. In part, that’s because the IDEA says that kids who receive special education services should learn in what’s called the “Least Restrictive Environment” (LRE). That means they should spend as much time as possible with students who don’t receive special education services.

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5 Inclusion Myths & Facts

Myth #1: Inclusion is easy.

Fact: Inclusion requires effort from all involved parties, and even then, it’s not a guaranteed success. Some of the steps you can take to make sure your child is included are:

  • Scouting out welcoming venues and making sure the sensory environment is appropriate.
  • Carrying a sensory toolkit to reduce anxiety in certain situations.
  • Identifying the times when extra assistance or patience are needed, and explaining your child’s needs to others.
  • Walking your student through his/her school schedule in an empty school the week before school starts.
  • Introducing your child to his teachers and helping him create an introductory portfolio.
  • Rehearsing situations and teaching etiquette proactively.

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An Inadequate IEP will Make it Difficult to Consider LRE Placement

An inadequate IEP will make it difficult to consider any child’s placement in an organized way. To assist schools and parents, the department has developed and widely distributed a model form that addresses all the required IEP components.

Next, each placement option is examined not only as it currently exists, but also as it might be modified. Then, each educational placement option is examined in sequence from least restrictive to most restrictive.

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Inadequate IEPs and a Child’s Placement in the Least Restrictive Environment (LRE)

PRN note: While this was written for New Jersey parents, the basic concepts apply in all states. The second factor listed is from a fifth Circuit Court case against a Texas school.

An inadequate IEP will make it difficult to consider any child’s placement in an organized way. To assist schools and parents, the department has developed and widely distributed a model form that addresses all the required IEP components.

Next, each placement option is examined not only as it currently exists, but also as it might be modified. Then, each educational placement option is examined in sequence from least restrictive to most restrictive.

Regular class placement is examined as the first option. In New Jersey, the decision-making process must include the three factors of the Oberti decision now incorporated into code and begins with consideration of placement in the regular classroom. Does this mean that each child must be placed in the regular classroom before other placement options are considered? The answer is no. The requirement for a continuum of placement options reinforces the importance of an individualized inquiry, not a “one size fits all” approach, in determining what placement is the least restrictive environment for each student with disabilities.

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Comments that Parents Hear: “We place all children with Autism here.”

The IDEA regulations put an emphasis on students being served at their home campus. Courts, hearing officers, and the Office of Civil Rights (OCR) have allowed schools to place some groups of students with disabilities on one or more campuses with non-disabled students rather than on every campus.

However, the law and regulations put a priority on the concept of students being educated with their peers and in the general education classroom to the extent possible. There also must be a “continuum of alternative placements” within the school.  Also a child with a disability is not to be “removed from education in age-appropriate regular classrooms solely because of needed modifications in the general education curriculum.”

Parents should ask for the rationale for this practice and if exceptions are made and under what circumstances. Chances are the district has made exceptions for specific students. The parent could then discuss at least an exception for part of the day. Placement decisions are to be individualized and should be reviewed periodically. One size fits all models are not individualized. Circumstances/needs could have changed so that the student could be returned to the home campus at least part of the day.

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Working with the ARD Committee on LRE

Your child’s IEP must be built upon the PLAAFP.  The PLAAFP should identify the needs of your child.  IDEA regulations say – “(6) In evaluating each child with a disability under Sec. Sec. 300.304 through 300.306, the evaluation is sufficiently comprehensive to identify all of the child’s special education and related services needs, whether or not commonly linked to the disability category in which the child has been classified. (7) Assessment tools and strategies that provide relevant information that directly assists persons in determining the educational needs of the child are provided.”  300.304(6)&(7)  A weak PLAAFP leads to a weak or inappropriate IEP, missing accommodations or modifications, and inappropriate LRE decisions.

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PPCD Preschool Least Restrictive Environment (LRE)

Least Restrictive Environment (LRE) is a requirement of the Individuals with Disabilities Education Act (IDEA) for all children, including preschool children with disabilities. Because providing preschool classes is not a requirement for local education agencies, finding natural environments for preschool-aged children with disabilities to receive special education services can be a challenge for school districts.

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Supreme Court Decision in Endrew F. Focuses on Mainstreaming, Progress, and Designing IEPs to Meet Child’s ‘Unique Needs’

What a great day! On March 22, 2017, the U.S. Supreme Court issued another unanimous ruling in favor of children with special needs and their parents.

The Court emphasized that full inclusion is the primary standard, with the “child progressing smoothly through the regular curriculum.”

The Court held that “merely more than de minimis” progress is not enough. Chief Justice Roberts wrote, “…IDEA demands more. It requires an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.”

If a child is not fully included, school officials must look at the child’s unique needs before developing an IEP that is “pursuing academic and functional advancement.”

The decision in Endrew F. is a great victory for those who advocate children being fully integrated in regular education classrooms.

Per the statute – unique needs = specialized instruction.

Read Pete Wright’s analysis of the Supreme Court decision in Endrew v. Douglas County.

Return to Data Collection

What do you know about your child’s unique needs? You will get information about your child’s unique needs from test data that measures your child’s strengths, weaknesses, and educational needs.

How do you measure the educational benefit? You look at changes in the test data over time.

  • Are your child’s standard scores, percentile ranks going up over time or going down?
  • Is your child regressing? Is he being damaged by an inappropriate educational program?
  • Is your child making progress and showing educational benefit?

We hope that the decision in Endrew F. will lead to a return to data collection and analysis of the data over time, instead of relying on subjective perceptions about a child’s progress.

Schools used to rely on data and objective measures of progress, before the 1991 decision in Shannon Carter’s case. After Carter, school districts stopped using objective tests to measure progress and embraced subjective “teacher observations.”

This is a great day! In Endrew F., the Court focused on educational progress, growth, and developing IEPs to meet the child’s unique needs, while also re-emphasizing the goal of integration or inclusion in regular education.

Congratulations to Endrew F’s parents and their attorney, Jack Robinson, Esq. of Spies, Powers & Robinson, Denver, CO. This was such a long battle. You lost at every level, until the Supreme Court agreed to hear your case, then ruled in your favor.