1. Compare different approaches to teacher certification as a result of inclusion.
2. Define the legal definition of adaptation.
3. Define the LRE test.
4. List objections of teachers to the concept of inclusion.
5. Define curricular modification and list examples, such as course substitution, time alterations, modifications in the curriculum, instructional methods, or materials, development of a special education curriculum corresponding to the general education curriculum, and alternative approaches.
6. Define quasi legal concepts related to inclusion, including teacher appeals of placement decisions, appropriate class size, ability grouping, class placement and full potential.
7. Define requirements for modification of buildings, supplementary services, parent involvement, and discipline.

Federal law does not require inclusion of all students with disabilities in regular classrooms nor even mention the term; case law and local practices are spreading the trend. While the basic rule in IEP development and programming has been to base decisions on the student's abilities and academic needs, which might dictate placement along a continuum of potential services, some case law now holds that social integration is equal to if not more important than academic needs.

Following the implementation of PL 94-142 in 1975, the "continuum of services" or "cascade of services" became a popular way to envision the provision of services for the least restrictive environment (LRE), which could be a placement ranging from full-time special class placement to a variety of options along a continuum leading to full-time placement in general education. Today the logic of placement along the continuum has been reversed. The premise is now that a school must justify why a child should be excluded, rather than parents justifying why a child should be included.

The federal mandate for the LRE remains . . . "all children with disabilities have available to them . . . a free, appropriate public education which emphasizes special education and related services designed to meet their needs." Provisions for the LRE were also broadened with passage of IDEA to include "instruction conducted in the classroom, in the home, in hospitals and institutions, and in other settings; and instruction in physical education." IDEA has also expanded the concept of potential benefits to the child beyond education to include integration in extracurricular activities, health services, recreation, clubs and organizations, and athletics.

A full explanation of how the LRE test may be employed was revealed in Statum v. Birmingham Board of Education (1993). The judge applied the LRE test by relying on the decision in Greer v. Rome City School District, an Eleventh Circuit decision, except the judge used a three-part test to determine appropriateness. The child in the case was a seven-year old girl with multiple disabilities who was confined to a wheelchair, exhibited symptoms of cerebral palsy, and had a tested IQ of less than 30. She had been placed in a regular education classroom of her neighborhood school, but the school proposed changing her placement to a segregated special class in a school several miles from her home. After a due process hearing, in which the school prevailed, the case ended up in the United States District Court of the Northern District of Alabama, where the judge ruled that the school district had failed to comply with provisions of IDEA, and the judge ruled that the child remain in her first grade regular education classroom with appropriate aids and services. The parts were:

1. assessment of the academic and non-academic benefits in regular education placement compared to segregated classroom placement;
2. whether or not the child had a disruptive effect on the regular education classroom and whether the child required a disproportionate amount of the teacher's attention and classroom time; and
3. the cost of educating the child in the regular education classroom.

Students will be integrated in extracurricular activities, if they cannot be included for academic subjects, but most likely they will be integrated without regard to academics. Students may be integrated in spite of a lack of progress in achievement, especially if they benefit socially. The first federal District Court ruled that "supplementary services" such as speech therapy or other services that are impractical in general education could justify removal from the classroom for some portion of the day, but the child would be considered a member of the class. Class membership in general education is considered to be important for social and educational reasons.

At issue today are reasons to exclude a "particular" child, which may include disruptive behavior, too much demand on the teacher's time, an inordinate demand for curricular modifications, or fragile health that might be threatened in general education classroom setting (Martin, 1994). In such instances, the school might argue that other students in the class will be harmed, the class will be too disrupted, or the child may be endangered. The opposite arguments might be that the school could modify the child's behavior, as was done in Oberti, and/or the teacher should have more training to deal with classroom management and curricular modification (Martin, 1994). Martin (1994) reported that some courts might decide that extraordinary curricular modification that renders the curriculum to be "unrecognizable" might cause a determination that the child should be in a different setting, as ruled in the Fifth Circuit Court opinion, but social integration seems to be off-setting this guideline. In general, the following conclusions can be made about the LRE and inclusion, summarized from the reports of Osborne and Dimattia (1994) and Martin (1994):

1. All children with disabilities are not required to be placed in the general education environment.
2. Children with disabilities may not be excluded because the school finds it less difficult to educate the child in a segregated classroom.
3. Just because a child cannot keep pace with peers in general education is not justification for exclusion.
4. Just because curriculum modification puts a burden on the classroom teacher is not justification for exclusion.
5. Social benefits from participating in general education may be of equal importance to academic training.
6. Children whose behavior impairs the learning of other students may be excluded, but attempts, such as training of the teacher or different management of the child, may first have to be demonstrated to be unsuccessful.
7. Excessive costs of "supplementary aids and services" to accommodate a child in the mainstream may be reason to justify exclusion.

Overall, courts have ruled that students may be removed from regular educational environments only if the nature and extent of the disability makes it impossible for education to occur in regular classes with the use of supplementary aids and services. The courts have put the burden on the school to prove that an alternative placement will be more satisfactory.
 

Woodrow Wilson Elementary School Northeast Arkansas School District "Inclusion is the commitment of our faculty and staff to educate each child to the maximum extent appropriate in the school and classroom.  Inclusive education helps to improve socialization skills and self-esteem.  Implementation from kindergarten through the fourth-grade allows students to learn to work together in an inclusive society.  Our belief at Woodrow Wilson is that all children must participate equally in all areas of school." _______________________________ A consolidated district comprising the former districts of Oak Grove, Stanford, and Paragould.  Over 2,800 students are enrolled in five elementary (K-4), one middle school (5-6), and one high school (7-12).  Additionally, the district maintains:  The School of the 21st Century, a comprehensive child-care center for infants and toddlers, and a before/after school care program at the elementary schools.

In Honig v. Doe the court ruled that a change in placement may occur only when a placement committee meets with the parents and a new placement is proposed. If the parents disagree, the student must "stay put" and the school system must initiate hearing procedures. However, a student who endangers the safety of others may be barred from school by the court until the hearing is conducted. Similarly, in S-1 v. Turlington, the court ruled that only a trained and specialized group is qualified to make placement decisions, and a student cannot be expelled if his or her behavior is a manifestation of underlying disabilities.

 In S-1 v. Turlington (1981) the court held that a student with disabilities cannot be expelled until an assessment is made to determine if the misbehavior is related to the disability, and that expulsion comprised a change in educational placement. In Honig v. Doe, the U.S. Supreme Court made rulings that require schools to handle disciplinary actions of students with disabilities differently from other cases.

Suspension is the removal of a student from the school for a period of up to ten days. Expulsion is a more "permanent" removal of the student for the remainder of the semester or year. Removal of a student from education can be accomplished only after formal due process. Suspension and expulsion are problematic issues with any student, but especially difficult when the student has disabilities because it is considered an extreme form of discipline.

A child with disabilities can be suspended or expelled if the cause of the disruptive behavior is something other than the child's disability. Students with learning disabilities can be expelled for one year if they bring guns to school, a special attachment to the Elementary and Secondary Education Act of 1994. A student may be suspended if the misconduct is the result of a disability if his or her presence poses a danger to himself or herself, to other students, the school staff, or if the student's conduct is so disruptive over a period of time that normal classroom activities cannot continue.

In  (1979) the court determined that the school could not expel a student if the cause of the disruptive behavior was the result of the child's disability. This position was upheld by the court in S-1 v. Turlington (1981).

Alternatives to expulsion and suspension include time-out and after hours or "in-house" suspension. If the in-house suspension interferes with instruction, it may also be considered a change of placement, however. If in-house suspension lasts 10 consecutive days, due process procedures must be followed. Expulsion requires the following steps:

1. written notice to the parents or guardians;
2. a formal hearing before the board of education at which the superintendent presents the evidence of the student's wrongdoing and the student, or the student's lawyer or lay counsel, can present evidence of the student's innocence;
3. an opportunity for the student to see and challenge all of the evidence presented against the student;
4. an opportunity for members of the board to question all parties; and
5. a formal written decision by the board to expel the student, to reinstate the student, or to administer less severe punishment.

If disruptive behavior is to be used as a reason for excluding a child from general class placement, the problems of interpretation will once again be raised. Disruptive behavior can be "in the eye of the beholder," because there are no "norms" for comparison unless the school keeps accurate data on all occurrences of misbehavior for all students. The burden of proof will be on the school to show why a child's behavior is so disruptive as to cause exclusion from the classroom and that such behavior is truly different from others in school.

Ways to accommodate or modify the materials, methods of instruction, and the curriculum for students with disabilities are many and varied, and some of them are based on common sense approaches. For example, students who are blind cannot read but they are always permitted to have braille books, readers, and tape-recorded lessons. Nobody questions that this is a suitable accommodation but the same considerations are not permitted for students who do not read efficiently but who have good vision. The method of modification should be stated in the IEP so the classroom teacher will recognize that it is a consideration of the committee that must not be ignored. Methods of accommodation include (Podemski, Marsh, Smith & Price, 1995, p. 118-119):

1. Course substitution. This approach is used when the disability prevents the student from taking a course or would make such a course meaningless. Examples are substituting adaptive physical education for physical education and, in the case of a students with hearing loss, substituting music history for music appreciation.
2. Time alterations. This method allows students to take longer to complete individual courses or courses of study. The IEP may be used to design and specify time requirements and other aspects.
3. Modifications in the curriculum, instructional methods, or materials. There are many instructional aids available---for example, taped lectures or books and braille books--that can help the student achieve class objectives. Alterations in the reading levels of tests can also be used to help the student achieve certain objectives.
4. Development of a special education curriculum corresponding to the general education curriculum. In this approach the curriculum objectives for general and special education are the same, but the instructional methods are different, suited to the student's needs.
5. Alternative approaches. Other methods a school may use to help students achieve graduation are work study programs, work experience, vocational or job entry/early graduation, college entry/early graduation, independent study, and night classes or high school equivalency tests.

Class size is certainly related to expense, which has implications for teachers' salaries and other benefits. The majority of the local school budget---80 to 85%---is dedicated to teachers' salaries and benefits. Larger class size could mean that teachers could receive higher salaries; lower class size many mean salaries will be lower. The more teachers needed to accommodate smaller class size and the more classrooms are needed, the greater the costs. For example, the argument might be that if each teacher could accept one more student, for each group of 20 students there would be a savings of one teacher's salary at the elementary level, which could be used for salary increases. In recent years local taxpayers have been reluctant to support tax increases to support education, and smaller class size would dictate a need for more taxes. Nonetheless, teachers and others may request smaller class size, especially if the demands for inclusion continue to increase at the current pace.

Oakes, Gamoran, and Page (1992) reported that school performance tracking creates social inequality outside the school by separation of students along racial, ethnic, and social lines. The National Education Association and the National Governors' Association have both recommended discontinuation of conventional tracking practices. Detracking is based on concepts similar to those used to endorse inclusion, that tracking is detrimental to low-ability students. The main issue is the potential to track on the bases of class and race. There is evidence to show that "gifted" and students in higher level tracks can drop slightly in achievement if they are enrolled in a heterogeneous class (Brewer, Rees, & Argys, 1995). As Brewer and colleagues indicated, there may be a small overall gain in efficiency associated with ability grouping, but it also raises an equity issue because tracking exacerbates the achievement gap between low- and high-ability students. Slavin (1987; 1990) reports positive effects for within class grouping for math and cross grade grouping for reading, resulting from the nature of the activities involved and not the grouping per se.

Tracking at the secondary level has often involved a "watered- down curriculum" with restricted enrollment for students with disabilities and low achieving students. In Mills v. Board of Education of the District of Columbia (1972) and Hobson v. Hansen (1967), the courts held tracking to be discriminatory, but the practice still persists in states outside the districts of these courts. Recent court decisions related to tracking, ability grouping, curriculum modification, and related issues may spread the ban against tracking under terms of an "appropriate" education. Tracking is segregation. Tracking is especially detrimental when rules require that students must take all low-track courses if they take one such course. For example, a child with good ability in mathematics would have to take the "low track" math class if he or she were enrolled in a basic English class.

Brewer, Rees, and Argys (1995) have summarized research about tracking in education. The following points have been adapted from their review:

1. Some forms of ability grouping appear to be beneficial, when students are grouped for only one or two subjects while remaining in heterogeneous classes most of the day.
2. Between-class, whole-day ability grouping at the elementary level has little or no positive effect on student learning.
3. There is little evidence that students at the secondary level benefit academically from being in tracked classes
4. Current practices of tracking do more harm than good for the overall educational achievement and attainment of low performing, students at risk.
5. Current practices of retention has few positive and mostly negative effects on student learning.
6. Retention produces negative results on such measures as academic achievement, personal adjustment, self-concept, and attendance.
7. Chapter 1 programs displayed modest positive effects on students' reading and math skills, but they were less effective for the most disadvantaged children. Students' progress was rarely sustained beyond 2 years after participation in the program.

The case dealt with the question of whether or not a pupil with hearing impairment would benefit maximally in general education, or if placement in a special class would meet the child's needs. The decision reversed previous decisions and concluded that Congress did not intend that schools should maximize the educational performance of students with disabilities. In other words, the child was not entitled to a better program than other students. Put another way, because other students do not get the "best" in schools, it is not necessary to require the "best" for students under provisions of IDEA. While this would seem to answer the question posed above, it would also seem to conflict with recent lower court decisions about curriculum modification, teacher training, and supplementary services to accommodate the child in general education.

While Section 504 regulations do not require that every classroom or school building be accessible, the specific educational programs that are appropriate for students must be accessible, and under inclusion this means all classrooms and not just those for special education. For construction started after the implementation date of Section 504 (June 3, 1977), regulations require that it be designed so as to make all or part of the facility accessible to students. In designing new construction, recipients are required to comply with accessibility standards of the American National Standards Institute (Sec. C, 84.23). PL 99- 457, passed in 1986, was an amendment to PL 94-142. This law lowers the age of mandatory services for students with disabilities to ages 3-5 years, so there could be implications for classroom space and design.

PL 101-336, the Americans with Disabilities Act (ADA), was passed in 1990. Title I of the Act addresses reasonable accommodations and essential functions. Title III addresses "readily achievable" accommodations, reasonable modifications, and provision of auxiliary aids and services. The 1990 Individuals With Disabilities Education Act (IDEA) guarantees "that all children with disabilities have available to them . . . a free appropriate public education which emphasizes special education and related services designed to meet their needs." One change that may have implications is expansion of the definition of "special education" to include "instruction conducted in the classroom, in the home, in hospitals and institutions, and in other settings; and instruction in physical education." The implication may be that classroom instruction that does not meet the needs of included children may be questioned, including the environment and instructional methods of the teacher. For example, if noise in the classroom is a serious problem for some learners, schools may be forced to renovate classrooms to reduce noise and otherwise improve the conditions of learning. The special needs of students may imply the soundproofing of walls and use of carpet and other floorings and acoustical ceiling tiles to reduce extraneous noises that might prove distracting or interfering.

It is unreasonable for classroom teachers to expect that every included child will have his or her own full-time aide. The process is individualized. Moreover, many classroom teachers are unaccustomed to supervising aides and some have problems when they must do so. The most common supplementary services are likely to be training for the teacher to deal with the needs of the student and consultation with professionals who can be of assistance. Assistive devices may also be provided, enabling the student to benefit from classroom instruction. In rare cases where students have more serious health problems, a variety of monitoring devices will be required.

The American Federation of Teachers, represented by Albert Shanker, has taken the position in more than one forum that funds allocated to inclusion will divert funds from regular education and cause schools to deteriorate. Shanker took this argument to the New York Times (Sept. 19, 1993). Laurence Liberman wrote a letter to the editor, published in Education Week (Dec. 16, 1992), asserting that inclusion is simply a way to save money by "dumping" special students into regular classrooms. While both oppose inclusion, one believes it will be costly and the other thinks it will be done to save money.

Strain and Guralnick (1994) conducted a longitudinal study of preschool integration involving 400 children and their families in 250 preschool and elementary classrooms. They found placement cost savings for the preschool integrated group totaled approximately $26,000 per child through grade three. A study by the Clark County Special Education Cooperative of Indiana (1993) showed that the cost per pupil comparison between inclusion and traditional service delivery programs is minimal. McLaughlin and Warren (1994) concluded that inclusion does not cost more than other modes of service delivery, and in the long run may be less expensive. Salisbury and Chambers (1994) conducted a longitudinal study of inclusion costs in the Johnson City School District, Johnson City, New York. The five year study concluded that costs were significantly less on an annual basis relative to comparable costs for out-of-district services. There was a significant increase in the number of students with severe disabilities during the five-year period but costs were well below that of out-of-district services; related service costs doubled because of the initial increase of more students with more needs; and, there was an increased reliance on paraprofessional staff for support in the regular classroom. Overall, the costs were significantly lower.

Vergun and Chambers (1995) studied the relationship between costs and benefits of supported (inclusion) education practices in ten schools within nine Oregon school districts, and they found that transportation costs increased initially to make buses more accessible, but declined in the long term because of shorter distances traveled by students being served in neighborhood schools. It was also found that costs of adapting buildings for accessibility were considerably lower for newer buildings than older buildings. The greatest need expressed by schools was the additional support for staff development.

For many administrators and politicians, the basic question will be. Does inclusion save money or cost money? It depends on where you live, of course. If a particular state has incentives or disincentives built into certain state funding formulas for inclusive practices, then there are likely to be different results.  The Center for Special Education Finance (1994) has reported that ways of funding special education create incentives that lead to over identification and restrictive placements. Making inclusion a "funding neutral" issue would force the matter back to a focus on the child.

Mawdsley (1995) asserts that it is difficult to determine if inclusion will produce resource economies for school districts. There is apparently no savings in personnel costs, although there is a reduction in transportation expenditures. Roahrig (1995) compared costs (i.e., instruction, administration, transportation, and staff development) related to inclusive programs in four elementary schools with costs for traditional special education services in nine elementary schools. It was concluded that both programs were equally cost-effective.  For a detailed analysis of special education costs in one state, see the study concerning Minnesota.

Questioning the efficacy of special education or its funding invites both logical and emotional attacks.  However, policy makers have reached a point where they can no longer avoid these issues. Money for special education is a mixture of federal, state, and local funds. Special education costs per student are about 2.3 times the costs of a regular student (Parrish & Chambers, 1996).  When P.L. 94-142 was enacted in 1975, the U.S. Congress committed to provide 40 percent of special education funding, but the federal contribution has never been near this level, in most years supplying less than 10 percent.   In almost every state there are few issues more troubling to legislatures than funding methods for special education costs (DeVries, 1998).

At the local level many parents and board members are concerned because of the mandate to serve students with disabilities but find the local budget shrinking each year and being tapped to make up the shortfall in state and federal contributions. In California, for example, the ratio is 70% state, 25% local, and 5% federal (The Little Hoover Commission, 1997). In poor districts, which also commonly have more students with disabilities, the local contribution is often higher as a proportion of funding.  Gerwin (1998) reports that special education in Massachusetts now exceeds $1 billion a year and in California it is nearly $3 billion annually.  The demand to get full support has stimulated litigation in Michigan, with districts suing the state. In Pennsylvania the state subsidy covers only 22% of local costs, and districts in New Jersey have asked for emergency funding to support the cost gap.

There are other costs associated with special education that are not reflected in the K-12 funding patterns. The U.S. Department of Education (1999) reports a critical shortage of personnel to meet the needs of children with disabilities. In 1995-96, more than 4,000 full-time-equivalent special education teaching positions were vacant and an additional 28,000 special education teachers were not fully certified for their positions. The need for related service personnel was seen as even more critical, with over 6,000 vacancies and almost 45,000 service providers not fully certified.  Many of these people would be certified and employed to deliver services to older children who have limited prospects reading improvement.  For learning disabilities, however, one can question just how helpful special education is in meeting the needs of children (Krantz, 1997).

The efficacy of special education programs has long been questioned (Johnson, 1962; Goldstein, Jordan & Moss, 1965; Dunn, 1968), and its efficacy remains questionable today.  Slavin (1989) concluded that special education assumed a substantial burden in attempts to meet the needs of students at risk of school failure. Longitudinal studies show that 74% of children who are poor readers in the third grade remain poor readers in the ninth grade (Francis, Shaywitz, Stuebing, Shaywitz, & Fletcher,  1996).  The investment of millions of dollars in personnel preparation, salaries, assessment, therapies, and remedial programs has not been successful.

The future of special education seems to portend many conflicts of parents of special education students and other parents who believe special education is an encroachment. This process has already begun with charges and counter charges in several states.  The accusations include: costs are out of control; fiscal malfeasance; special education is an entitlement; a free appropriate education is a license for under-education; and special education has spawned a cottage industry of specialists who live off the public funds meant to serve children (Peyton, 1998).  While attention-deficit disorders is growing by leaps and bounds, the majority of special education students today are said to have learning disabilities, about half of all labeled students.  Perhaps much of this conflict can be averted if policy makers would turn their attentions to early reading problems.  Inexpensive early detection and routine, appropriate instruction for millions of young children with dyslexia may be the most important policy issue in special education and for peaceful resolution of emerging conflicts among different advocacy groups.

Another alternative might be the "dual certification" of teachers in a subject area and in special education. Such programs have been proposed for early childhood (Burton, Hains, Hanline, McLean, & McCormick, 1992; Miller, 1992). A program for elementary certification is reported by Iran-Nejad, Marsh, Ellis, Rountree, Casareno, Gregg, Schlichter, Larkin, and Covert, (1995), the Multiple Abilities Program at The University of Alabama. Another program is the inclusive elementary and special education teacher preparation program at Syracuse University (Meyer, Mager, & Sarno, 1991). See these links to each state for certification/licensure information.

In the near term, there are likely to be more shortages of personnel with a greater reliance on "emergency" certification and on the use of paraprofessionals.

Greater attention to non-discrimination training of school personnel can prevent problems with children and parents from diverse backgrounds. Coordination between bilingual general education programs and special education programs is a policy concern. Separate funding and statutes cause problems at the local level. The school can also address this issue directly by determining who has access to which services under certain conditions.
 

There should be a clear distinction in policy that differentiates ordinary disciplinary problems from violent and criminal behavior, an area confused by the general public. It should be noted that IDEA 97 has specific regulations pertaining to criminal behavior, drugs, guns, and provisions for students.  Schools can employ suspension, alternative placement and expulsion if misconduct is not related to the child's disability. The most common problems are ordinary behaviors, many of which would be acceptable in a different setting or context, including talking, teasing and kidding (McFadden, Marsh, Price & Hwang, 1992). Despite the public view and over dramatizations in the media, most schools in the United States are safe and there is not a great deal of serious trouble.

 In places where corporal punishment is allowed, and due to court decisions, it is possible to administer corporal punishment without a hearing at the discretion of the school administrators. Without arguing the merits of positive reinforcement, it is clear that this is a policy that can be abused. In other districts, the favorite method of dealing with behavior problems is by means of suspension, particularly the so-called "in-school suspension."

Students who have emotional and behavioral problems should not necessarily be punished for their behavior if it relates to the disability. While it is well known that punishment, either corporal or suspension, will not deter inappropriate behaviors, removal from the classroom through suspension effectively removes the child from the classroom, which can be supported by the teachers. The focus, however, should be on changing behavior and enhancing education for students with behavioral disorders. It is the responsibility of the school to provide appropriate modifications and interventions. Removal from the classroom is not therapeutic nor educational. An alternative setting should be provided if children are removed with adherence to due process procedures (see Honig v. Doe, ).

If a child is disabled or nondisabled, opportunities to cause problems in the classroom depend, in part, upon the policies of the school, the structure of the class, and behaviors of the teacher. Schools can reduce problems by identifying those who cause the most extreme situations. McFadden, Marsh, Price and Hwang (1992) found that the overwhelming majority of disciplinary referrals are accounted for by a relatively small group of repeat offenders. Consistent application of rules can address ordinary disciplinary problems and conflicts. The rules must stem from a policy that is based on fairness.

The most critical problem is to improve both the assessment/evaluation and IEP procedures. Teachers' views regarding the usefulness of the IEP indicate a lack of relevance for instruction. Investigation has failed to find a relationship between IEP goals and objectives and student needs (Epstein, Patton, Polloway, & Foley, 1992; Lynch & Beare, 1990). Lynch and Beare (1990) found little congruence between the instruction provided and goals, objectives, or student needs. Addressing the general curriculum and any required state assessments will put the emphasis clearly on educational results. While the paperwork burden may not be easily handled without changes at the federal level, schools could implement, nonetheless, alternatives to short-term objectives that erect annual objectives and outcomes.

More frequent reports of student progress than the six-week periods would better serve parents and students. Any type of classroom performance measures could document progress toward meeting short-term objectives, and together they would constitute a formidable body of data and information that could show proof of meeting requirements. School policy should address ways to improve and facilitate data-collection requirements, perhaps by means of technological assistance such as databases on a local- area network.

The recent trend to adopt vouchers and the refusal of the U.S. Supreme Court to hear an appeal about using tax dollars to support religious schools opens up a new area of concern in special education.  The issues surrounding vouchers are likely to become more complicated as time passes. In the matter of choice of schools, an anthem of many conservative groups, the real choice is with the private school that can choose to accept a particular student and also choose to terminate the student's enrollment.  Public schools have to take all comers, because they have no choice.  If public funds are used for vouchers, the selective private schools will admit the students with the most apparent ability and lack of behavioral problems.  This may leave many public schools with a significant financial loss as public funds follow the selected students into private sectarian and non-sectarian schools.  There is apparently no requirement, however, that a private school must accept a child with a disability nor provide the services associated with inclusion.  The authors have already been contacted by parents of ADD children who have learned that their children will be excluded from private schools after the diagnosis became known.