565 Comments

1. I opposed to the inclusion in early childhood programs , because they needed communication to help their education improvement. without that then there will be no education. first they closed the deaf school now this mainsteam school for small class for the deaf what now next the videp phone operator will be shut down because people continue to accept this oppression to go on . I cant allow that I am oppose to this kind of situation.

2. I oppose Inclusion of Children with Disabilities in Early Childhood for Deaf and Hard of Hearing. They fail to recognize the Deaf linguistic cultural community’s best interests. The continuum of services especially for the schools for the especially with direct communication
   Please do not push full-inclusion policy upon deaf children without consulting with professionals working with Deaf and Hard of Hearing children to access what is best for each individual child. (This is copied and pasted becau

3. Rehabilitation Act (Section 504)
   Thank you for referencing this law when discussing the legal foundation. This will be a big help in introducing and moving state legislation and local mandates forward.

   Purpose (Page 1)
   Although Charter Schools are public schools there is still some confusion across the country in this regard. Since there are Pre-K programs in some charter schools, in paragraph one perhaps consider including this phrase: public (including charters).
   Results Driven Accountability Initiative
   To encourage the understanding that quality is more than compliance, as compliance is not synonymous with quality results for children and families, perhaps consider on page 2 of the OVERVIEW section within paragraph 4, a mention of the Results Driven Accountability Initiative with a footnote of the RDA link on the Dept. of Ed website.
   Professional Development
   Although continuous or on-going professional development is mentioned a few times within paragraph text throughout the document a mention in bold print (page 9 section7) would help drive home the fact that Professional Development should be differentiated and on-going. Something like: Build an On-going, Coordinated, Differentiated Professional Development (PD) System.
   Glatthorn, A, Boschee, F. Whitehead, B and Boschee, B (2012). Curriculum Leadership; Strategies for
   Development and Implementation (3rd Edition). Thousand Oaks, CA pgs 280-290.

   Roberts, S. & Pruitt, E (2009). Schools as Professional Learning Communities Collaborative Activities
   and Strategies for Professional Development. Thousand Oaks CA pgs. 66 – 72

   Thank you for the opportunity to provide comments on this very important document. If memory serves me correctly, there were Dept. of Ed and/or HHS representatives at the DEC conference in October of 2014. DEC held a listening sessions with members regarding the preparation of this document. So much of what was said during that listening session is included within this document. I am looking forward to the final copy being ready for public consumption as it will be a definite help to my work as an Exceptional Needs Consultant as I work with LEAs, SEAs and public officials. Are you able to say when the final document might be available?
   Once again thank you for the document and the opportunity to provide input and feedback

4. I am Deaf and I was brought up in a mainstream setting. It was until 8th grade when I was finally able to transfer to California School for the Deaf. This is where I bloomed and my educational opportunities were maximized. I find the DOE’s proposed guidelines misguided and potentially harmful to untold numbers of Deaf children. The “full inclusion” of children with disabilities sounds great in theory but does NOT work for Deaf children. In the pathological view, deaf people are “disabled” by their hearing level. But how do you address the educational need and ACCESS to information that Deaf children desperately need. Mainstream, public schools across the nation are in horrible shape and in no way qualified to teach Deaf children. Deaf children are assimilated with children of other disabilities and passed through the system with no regard to their needs. Deaf children do not have a learning disability and are often misplaced in such environment that do not foster growth. They need access to Deaf teachers or, teachers that sign, preferably a Deaf school.

   Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

   With that said, I’d like to conclude, I do not support this initiative or IDEA. The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

5. I want to thank the U.S. Departments of Education and Health and Human Services for the policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. I support this policy and hope it will be officially released as soon as possible. The clear message in the policy statement about the benefits of inclusion and the resources provided in the appendices will help me as I advocate for my child. The recommendations for state and local education agencies will help change the system, so it is not as difficult for parents to find inclusive early childhood programs or as difficult for our children to be successful. An especially important recommendation is the inclusion of children with disabilities in proportion to their presence in the general population (natural proportions). The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond.

6. An educational setting is only inclusive if it meets the student’s needs. Implementation of this policy would essentially redefine least restrictive environment in such a way as to deny students access to the educational services they need and to which they are legally entitled. It flies in the face of IDEA and should be abandoned.

7. It seems that a lot of people have covered what I planned to say regarding ‘inclusion.’ As many said, it may not be the most appropriate for Deaf, Hard of Hearing or DeafBlind people. Overall, the proposal may be acceptable for other needs/services.

   In reality, I WANT to see more centralized resource centers for all disabilities. It does not have to be a state school, but a regional school so that students have like-minded peers to interact with. Myself, I was mainstreamed all my life and for the most part, I was ALONE. There was hardly anyone that wanted to interact with me as a Deaf person who is able to speak pretty good. Friends were far and few. This can be depressing for many, but luckily in high school, there were a few others that were deaf also. None of them were in my classes though except for my freshman year. That hurts ‘incidental learning’ especially when one is dependent on an interpreter for everything.

   LRE (Lease Restrictive Environment) has been misinterpreted too many times as using the nearest school as satisfying the criteria, when in fact it failed most other requirements including appropriate support services. Honestly, i still meet kids who are sent to Deaf schools after being found in the closest or left out in the corner of the classroom at a mainstreamed school today. TODAY???? Imagine that? That tells me inclusion is flawed and IDEA (Individuals with Disabilities Education Act), formerly the 1973 Rehabilitation Act, is well intentioned but not all resources are there. We need to save costs by using more regional or state schools that are like-minded as not all resources have to be spread out all over. For example, a county may have 20 elementary schools and most may have special services of some kind. Doesn’t it make more sense to centralize the resources to save money and to give students access to more ‘incidental learning’ opportunities.

   We need to give our kids a good variety of options to use and ‘inclusion’ actually could close down state schools.

   If I were you, i would meet families and kids of such schools – autism, blind, behavioral, deaf, etc. Of all disabilities, one of the most challenging may be DeafBlind as two of their senses are gone or limited whereas others may just have one sensory challenge to deal with. You might find that these kids feel more at HOME and are happier, thus can LEARN better!

   Do feel free to contact me or anyone else about our ‘inclusive’ experiences as i do know several like me. Also, do consider our existing laws as we do not need more contradictions. Only clarity is what we ask.

8. I am speaking as both a professional who has been involved in the education and community of Deaf people, and as a Deaf person who was “fully included” long before the term ever became popular.

   Growing up, I attended my local public school. I could speak well, and managed to understand most of my teachers through lipreading and did well academically. Yet, I was socially isolated for most of my educational experience, and at some points, even bullied by my peers mainly for the fact that I was “different” from them — that I was Deaf. I experienced a continual sense of myself as not being able to “fit in”, that I was not “equal” to everybody else.

   After several years of that bullying, I asked my parents to allow me to attend a school for the Deaf. It was at the school for the Deaf that I finally gained a sense of confidence in myself, found the ability to make and maintain multiple friendships, and gained a secure identity as a Deaf person, rather than as a “broken Hearing” person. Moreover, I learned how much different and enjoyable education can be when one is not learning through a third party or having to work to understand what is being said.

   For these reasons and many more, I find the DOE’s proposed guidelines misguided and potentially harmful to untold numbers of Deaf children. Deaf people have a need for direct access to education (unfiltered by third parties such as interpreters), direct social interaction with peers who understand them and their experiences because they share those same experiences, and opportunities to learn how to live their lives as a confident, healthy Deaf person. No matter how well-structured a “mainstream” program may be, they can never provide the same opportunities for healthy identity, social, linguistic and academic development that Deaf students gain from center schools/programs for Deaf students.

   IDEA mandates the provision of a continuum of educational options. Removal of this continuum is not only against the law, it is against the spirit of IDEA as it was created. I strongly urge you to not only revise your proposed guidelines, but strengthen them by providing stronger avenues to the provision of Deaf-centered education for our Deaf student population. Without this, our current educational and social crisis within the Deaf community will continue as it has been since the creation of PL 94-142/IDEA, and this situation is truly untenable.

   • After 44 years as an educator of deaf children I find it remarkable that I once agin find myself commenting to the United States Department of Education regarding the unique linguistic and communication needs of deaf children. Why is this policy statement necessary? Children with disabilities are protected under IDEA and other mandates already.

     IDEA mandates a continuum of educational options to meet the individual needs of the child. Its intent is to start with the child’s needs which are determined through IFSP/IEP, and to then determine the best educational setting on a continuum to meet those needs. It is also very clear in taking in to account the unique language and communication needs of a deaf child.

     Why then is it necessary to issue this policy statement which starts with a predetermined placement option for all children and neglects consideration of the individual needs of the child? This policy statement is dangerous for deaf children. Most deaf and hard of hearing children develop best in a peer group of like language learners and with experienced educators of the deaf. An inclusion environment most often does not provide this.

     I join the chorus of deaf individuals, parents and educators of the deaf in opposition to this policy statement.

   • I oppose this policy ” Inclusion of Children with Disabilities in Early Childhood Programs” for Deaf and Hard of Hearing children.

     I support the need for a continuum of services for the Deaf and Hard of Hearing children because the children vary in their communication and language abilities. Please preserve the continuum of educational placement options as considered as freedom of choices what would be best for the individuals’ needs

     Again, I strongly oppose this policy statement and would encourage the U.S. Department of Education and U.S. Health and Human Services to recognize that children who are deaf/hard of hearing have unique needs that must be met in a unique way.

     Donald A. Galloway
     Superintendent/CEO
     Lexington School for the Deaf

9. I wholeheartedly support this but feel the underlying infrastructure is too weak to support it if the money to train and hire individuals isn’t backing it. If there is grant money available then yes. I have worked in Special Education for over 8 years.

   So many children are still being forced into non inclusive environments when schools provide transportation and concentrate services offsite. All kids should be provided inclusion so they can learn from their peers, especially the most disabled.

   One thing missing from my years of working in this area is there is not nearly enough training and educational money going to teach the teachers or staff of those involved in these jobs. Schools hire aides at a low pay, no training what so ever, and no benefits. Even when the schools are the LRE, without proper training of professionals and teachers it will be hard to have students be successful. More education requirements = more money to train staff (which is highly trained in there field of study, but untrained at dealing with special needs). Otherwise, schools will say they don’t have the money. Most preschools are not spending the money on qualified staff.

   Without the training and support for support staff all parties will continue to be isolated. Support staff can act as a pillar of support for the child, as a bridge to parents, as an extension of the teacher. But only if they are respected, trained and empowered. Without this the whole system fails–I have seen it. And the biggest loser in this situation is the child, as they fall behind another year, never to make it up. I hope I can provide additional help to encourage this in the future!

10. As an aspirational policy statement building on the joint NAEYC/DEC position statement, Parents as Teachers National Center wholeheartedly supports the vision of building a ‘nationwide culture’ regarding the inclusion of children with disabilities in early childhood programs. We agree that all children deserve the best and most inclusive start in life and that experiences in the youngest years impact the success of all children in school, career and life. We appreciate the continued collaboration between the two departments to focus on achieving the best outcomes for children in the birth to five space as has been our experience with implementation of the Federal Maternal Infant and Early Childhood Home Visiting (MIECHV) program. And, we appreciate the work to develop recommendations to states and programs.

    Arriving at a shared national definition of inclusion, establishing it’s appropriateness for all children and its implications for policy, practice, and potential outcomes for children and families is essential for us to understand what a nationwide commitment to inclusion requires. The NAEYC/DEC statement notes that access, participation, and supports are the defining features of high quality. Participation, as stated in the HHS/DE paper, must be facilitated by individualized accommodations and evidence of what works. And, there must be a concerted focus on staffing, training and ongoing professional development. While the HHS/DE policy statement suggests that inclusion is not more expensive than providing services and resources separately or through pull-out, funding for services for children with disabilities and for early care and education is currently inadequate. Re-allocating resources and braiding funding streams might help in reaching the inclusion goals of this policy statement, but only if there were sufficient resources and funding streams at the outset.

    The challenges to inclusion outlined in the statement are real and overcoming them will take time and funding. For one example, staffing, training, and ongoing professional development of the early childhood workforce—including family, friend, and neighbor care providers that are the most common providers of non-parental care in the US—bears a significant cost. Robust investment in the early care workforce is a critical foundation to facilitate inclusion. Similarly, additional resources must be targeted towards making comprehensive services available in every community.

    Opening up this national dialogue through dissemination of the policy statement and requesting community feedback is a good step towards helping serve more children in inclusive programs that are high quality.

11. When therapies are delivered “on-site,” as they should be, it is critical that they be delivered in the general classroom, not in a pull-out space that is being used as a therapy room.

    (page 8) There is a valid, reliable, evaluated instrument for measuring inclusion quality. It is call “The SpeciaLink Early Childhood Inclusion Quality Scale” is is available through “www.specialinkcanada.org”.

12. PEAK Parent Center is the Parent Training and Information Center for Colorado and also a Regional Parent TA Center serving PTIs and CPRCs in Colorado, New Mexico, Kansas, Nebraska, South Dakota, North Dakota, Wyoming, Montana, Arizona and Utah. PEAK has been a leader for over 30 years in sharing evidence-based inclusive practices for families and professionals. PEAK Parent Center strongly supports the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education.

    PEAK Parent Center has seen first hand the benefits of inclusive education, including inclusive early childhood experience. Most of PEAK staff are parents of children with disabilities that have had the benefits of inclusive early childhood education and have had many inclusive life experiences. We hear from parents every day that are navigating the education system, some share the successes of inclusion and some are still working within their schools and communities to realize inclusive opportunities but one thing is clear families want inclusive early childhood experience for their young children with disabilities. Early childhood inclusion builds on a children’s strengths while still providing supports that young children need. Early childhood programs help families build the confidence they need to advocate for inclusive schools and communities, as their children grow. These early learning experiences are the building blocks for inclusive elementary schools, secondary schools, inclusive post secondary and most importantly inclusive lives, in which people with disabilities live rich, active lives participating as full members of their schools and communities. PEAK Parent Center believes that it is important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring. Currently an early childhood setting is counted as a regular early childhood inclusive program if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”. Currently the OSEP data collection does not distinguish between a child attending a regular education early childhood program that is provided by the school district (in either a public or private setting) and one that is provided by the parents. In order to ensure transparency as to the district’s role, the data collection should be changed to reflect this important distinction. PEAK has been a beacon of hope for families as we have strongly supported early childhood inclusion for the past 30 years and we are pleased to see the progress made in this field. We commend HHS and ED on this important joint policy statement that will help us as we continue to work with families, school districts, and typical early childhood programs in Colorado.

13. This “inclusion” proposal cannot exist for deaf and hard-of-hearing children because of their unique language and visual needs. Barbara Raimondo was right when she stated, “Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.” As a deaf student, as a teacher of deaf and hard-of-hearing students, and as a parent of deaf children, I am a living example and I have worked with students who went through those so-called inclusion programs (regular classes with hearing peers). I always tell people that I am actually 7 years younger than my age mentally and socially because I did not develop strong social skills when I attended middle school and high school with regular hearing students.
    Growing up as an oral deaf child, I have lived through the difficult communication mazes when I went to a nursery school with hearing peers and then onto Kindergarten in a public school. I was totally bored and lost because I did not always understand what people said or when I did understand, I already missed critical points. (I was very fortunate to have strong communication at home with my family). Thankfully, I attended a school for the deaf from the ages of 7 to 10 where I thrived happily with deaf peers. I was able to talk with them every day and ask my teachers questions. I felt at home. Apparently, I learned so much in a short time and teachers encouraged my parents to send me to a small hearing school because I needed the challenges. So, I went on to a private school. My hearing classmates were great and yet I still could not keep up with their conversations. My voracious reading as well as my curiosity helped me succeed in school. BUT I felt alone and I missed so many nuances. I lived for weekends so I could see my deaf friends.
    After high school graduation from the hearing private school, I continued on to Rochester Institute of Technology because of their National Technical Institute for the Deaf services (note-taking and interpreting). When I arrived on that first day, I saw flying hands and I saw people my age. I felt as if I returned home. I attended hearing classes with sign language interpreters for the first time and I did not realize that I had to watch the interpreter relaying what the professor and the class were saying. I also took some classes with deaf peers and professors who provided direct communication instead of the third-party interpreter. I thrived on the direct communication. I learned to participate in discussions with deaf peers while it was virtually impossible for me to do so with hearing peers and even with an interpreter.
    Back to the “inclusion” plan and the point of my “stunted” social skills, it was at RIT when I learned to interact with people and it was difficult for me to accept my numerous gaffes in these interactions. After getting my bachelor’s, I worked in an inclusive classroom at a public school while I was going for my master’s in deaf education. Those poor kids were starving for communication and they were socially inept as well. I taught in two different schools for the deaf in two different states. These students who had full access to the visual sign language at an early age were utterly normal. There is plenty of research on this. But I want to emphasize how I would work with students who came from inclusive hearing schools had so many gaps in their language and social skills. Some of them caught up quickly due to deaf peers, direct communication, and motivation while some of them could not catch up.
    Furthermore, I happen to be a parent of two deaf adult children who graduated from a school for the deaf. Both read above their grade levels. Both got their college degrees. They are well-rounded. To be quite frank, my children have helped refined my social skills! They are literate. They are emotionally intelligent.
    Please visit schools for the deaf’s early education programs and see how the babies, toddlers, and young Elementary students communicate and learn comfortably in a language-rich visual environment.
    It is critical that the U.S. Department of Education separate deaf and hard-of-hearing children from this proposal. It is essential that deaf and hard-of-hearing children are not included in the category of “inclusion” education.

14. Please omit the phrase “several days a week” from paragraph ending at the top of page 4. We have learned that if almost all children attend 5 days a week, the child with a disability or delay is often left out of play or themed activity, if he attends ‘several days”. For example, if a child who attends only 3 days a week while most of the other children attend 5 days, the natural consequences of negative behaviors are often lost. Let’s say this child knocks over block structures. Another child might say “You can’t play with us. You knock over the blocks.” If he is not there the following day, but comes back in two days, the other children are not likely to remember the block knocking, and the opportunity for natural consequences is lost (you knock down my blocks; you can’t play).

    We often see that when a themed activity develops over 5 days, the child with the delay often misses the point. Think of a theme about fire and fire stations, one that starts on Monday with a story book about fire stations, followed the next day with play with fire trucks, boots, fire hats. And leads to a trip to the fire station on day 5, after 2 more days of activities. The child who has trouble grasping the ideas and vocabulary of the regular program is often lost if he misses out of the Tuesday/Thursday activities.

    This may seem simplistic, but the 3 days (with another child getting 2 days) is often the way that budgets are stretched to include more children with disabilities (sometimes it is mornings or afternoons, while most of the other children attend full time). If social inclusion is a major goal, the children with disabilities need the same amount of attendance as other children, and maybe more. Please do not restrict him to “several days.”

15. Thank you for the opportunity to comment. Hopefully this short period of time at this time of year, allows for enough input from stakeholders.

    A draft policy on inclusion should simply state that inclusion does not exist in law. IDEA requires students/children with disabilities must be served in LRE/Natural Environment. The policy should restate the requirements of law, not create policy that is not supported by law, regulations or Congressional intent.

    Why can’t we work together to build a culture of communication, coordination, competency and community to support everyone working together to ensure ALL children with disabilities receive the services they require to address their individual needs. This policy restricts service options, funding, materials, training, information and the ability of service providers in separate settings to utilize their special education skills and training.

    We agree that a majority of students with disabilities are best supported in regular education classrooms/natural environments, a policy such as proposed for promoting inclusion, is not in line with law and regulation, and wrests the placement decision from the parents and professionals comprising the IEP/IFSP teams. This proposed policy would conceal options on the continuum for students who are most appropriately served in these settings and give the decision making authority to the Department of Education on what is “best” for students. This policy suggests a “one size fits all” model and does not support the civil and educational rights of students and parents, who are promised the continuum of services be available, not pitched inclusion on every level, to truly meet the needs of individuals with disabilities.

    We also agree that much more training needs to be done at all levels to ensure that all students with disabilities, wherever they are placed, are provided services in high quality programs. Specialized training should be constant and consistent across all states. It should also include training on what is required by law to ensure that all families have all the facts they need to get the services they feel are appropriate when working with the IEP/IFSP Teams. As you know, although the law is clear, options for appropriate services differ from state to state, community to community and school to school. We also know that parents don’t need a policy to try and convince them of what is appropriate for their child, they already know. They just need all of the information, not just what you would like them to know, to get appropriate services.

    The draft policy interprets studies and laws to support its philosophy; however, there are just as many studies with outcome data and parent real life experiences to show that a “one size fits all” system does not work for everyone. Although you did add the “continuum and appropriate and took out “the sentence “there is more work to be done to reach full inclusion” to this version of the draft, it still violates what is required by IDEA. IDEA lays the foundation to ensure students are served based on their individual needs, not for inclusion, as you state here.

    You also state that “preliminary research shows that “operating inclusive early childhood programs is not more expensive than operating separate early childhood programs for children with disabilities”. NAPSEC also has two state cost studies that show that when students with disabilities need intensive services as outlined in their IEPs, the full cost to tax payers is less when services are provided by an approved private program, than when provided by either a local public school or a county special services district.

    NAPSEC also does outcome studies each year. For the 2013-2014 school year here is what we found:

    Transfer Students: 55% planned to enter or re-enter an educational program with their local public school district; 19% planned to enter or re-enter regular education settings, including regular education classrooms with supports in their home district. 94% were enrolled in the NAPSEC member programs for 5 years or less.

    The IDEA Conference Report – showing the Intent of Congress – states:
    IDEA’s Part B “Least Restrictive Environment (LRE) principle is intended to ensure that a child with a disability is served in a setting where the child can be educated successfully in the least restrictive environment. Through the Individual Education Plan (IEP) process the Team shall make placement decisions that are individually determined on the basis of each child’s abilities and needs.”

    For Early Intervention the IDEA Conference Report states “Congress recognizes that there may be instances when a child’s individualized family service plan cannot be implemented satisfactorily in the natural environment. The Conferees intend that in these instances, the child’s parents and the other members of the individualized family service plan team will together make this determination and then identify the most appropriate setting in which early intervention services can be provided.”

    When it comes to state funding formulas, Congress strengthened the provisions by stating ‘‘The conferees are concerned that some States continue to use funding mechanisms that provide financial incentives for, and disincentives against, certain placements. It is the intent of the changes to Section 612(a)(5)(B) to prevent State funding mechanisms from affecting appropriate placement decisions for students with disabilities. ‘‘The law requires that each public agency shall ensure that a continuum of alternative placements (instruction in regular classes, special classes, special schools, home instruction, and instruction in hospitals and institutions) is available to meet the needs of children with disabilities for special education and related services. State funding mechanisms are in place to ensure funding is available to support the requirements of this provision, not to provide an incentive or disincentive for placement. Part B’s LRE principle is intended to ensure that a child with a disability is served in a setting where the child can be educated successfully in the least restrictive environment. Through the Individual Education Plan (IEP) process the Team shall make placement decisions that are individually determined on the basis of each child’s abilities and needs. The new provisions in this section were added to prohibit States from maintaining funding mechanisms that violate appropriate placement decisions, not to require States to change funding mechanisms that support appropriate placements decisions.’’

    Separate and Served
    The Individuals with Disabilities Education Act (IDEA), requires instruction in regular classes, special classes, special schools, home instruction, and instruction in hospitals and institutions, it does not use the word “segregated” to describe separate classrooms and schools.

    The Draft Policy on Inclusion uses this term freely. It is an ugly word that raises ugly visions of the past. It also uses the word “moral” when supporting inclusion over separate classes. Neither of these terms are appropriate when addressing those students with disabilities that are provided individualized services based on their Individual Education Plan (IEP) or Individual Family Service Plan (IFSP) in an environment outside of the general education classroom/natural environment.

    These students are placed in the Least Restrictive Environment (LRE) – most appropriate environment – by professionals and family who participate on the IEP/IFSP Teams and know the child best. All special education placements are approved by and placed through public agencies. This process is in place to ensure that students get the most appropriate services even if they cannot successfully be provided in the general education environment.

    These special classrooms and special schools are staffed with individuals who selected special education as their profession and love working with children with disabilities. They are certified in their field and are continually trained to work with the special needs population. These professionals do not deserve to be dismissed and disrespected (How might resource allocation support special educators shifting from full time teachers to providing consultative services to early childhood teachers and community providers? Can we distribute existing specialized materials and equipment currently in segregated settings across general early childhood programs? Statements from draft policy statement).

    It is time to stop using ugly words to describe the continuum of alternative placements and services provided for through IDEA, and start implementing the law to ensure all students are served appropriately based on their individual needs. We need to show respect for those special education professionals who serve students that do not fit into a “one size fits all” special education system.

    The Department’s IDEA Regulation comments state it correctly…

    The law is clear and was reinforced in the Department’s comments in the IDEA Regulations. Nothing in the law has changed since the Department made these statements, the law supports what is written here, not what is written in the draft policy.

    Section 300.115 clearly states that the requirements for determining the educational placement of a child with a disability include preschool children with disabilities and that such decisions must be made in conformity with LRE provisions.

    Consistent with this notice requirement, parents of children with disabilities must be informed that the public agency is required to have a full continuum of placement options, as well as about the placement options that were actually considered and the reasons why those options were rejected.

    The Act’s strong preference for educating children with disabilities in regular classes with appropriate aids and supports, provides that States must have in effect policies and procedures ensure that, to the maximum extent appropriate children with disabilities, including children in public and private institutions or other care facilities, are educated with children who are nondisabled and that special classes, separate schooling or other removal of children with disabilities from the regular educational environment occurs only if the nature or the severity of the disability is such that education in the regular classes with the use of supplementary aids and services cannot be achieved satisfactorily.

    It would be inconsistent with LRE requirements in Section 612(a)(5) of the Act for a public agency to restrict the placement options for children with disabilities. Section 300.115, consistent with Section 612(a)(5) of the Act, requires each public agency to ensure that a continuum of alternative placements is available to meet the needs of children with disabilities.

    The overriding rule in 300.116 is that placement decisions for all children with disabilities must be made on an individual basis and ensure that each child with a disability is educated in the school the child would attend if not disabled unless the child’s IEP requires some other arrangement. However, the Act does not require that every child with a disability be placed in the regular classroom regardless of individual abilities and needs. This recognition that regular class placement may not be appropriate for every child with a disability is reflected in the requirement for LEAs to make available a range of placement options, known as a continuum of alternative placements, to meet the unique needs of children with disabilities. The requirement for the continuum reinforces the importance of the individualized inquiry, not a “one size fits all” approach, in determining what placement is the LRE for each child with a disability. The options on this continuum must include the alternative placements listed in the definition of special education under 300.38 (instruction in regular classes, special classes, special schools, home instruction and instruction in hospitals and institutions). These options must be available to the extent necessary to implement the IEP of each child with a disability. The group determining the placement must select the placement option on the continuum in which it determines that the child’s IEP can be implemented in the LRE. Any alternative placement selected for the child outside of the regular educational environment must include appropriate opportunities for the child to interact with nondisabled peers, the extent appropriate to the needs of the children, consistent with 300.114.

    The LRE requirements express a strong preference, not a mandate, for educating children with disabilities in regular classes alongside their peers without disabilities.

    The process for determining the educational placement for children with low-incidence disabilities (including children who are deaf, hard of hearing, or deaf-blind) is the same process used for determining the educational placement for all children with disabilities. That is, each child’s educational placement must be determined on an individual case-by-case basis depending on each child’s category of disability, and must be based on the child’s IEP. We believe the LRE provisions are sufficient to ensure that public agencies provide low incidence children with disabilities access to appropriate educational programing and services in the educational setting appropriate to meet the needs of the child in LRE.

    Conf. Rpt. Makes clear Congress’ intent that State funding mechanisms support LRE requirements and do not provide an incentive or disincentive for certain placement decisions, we believe the requirements in 300.114 accurately capture the essence of the Conf. Rpt.

16. On behalf of Pyramid Plus: The Colorado Center for Social Emotional Competence and Inclusion, I want to support this collaborative draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood programs. The policy is greatly needed and will benefit all children by providing quality inclusive opportunities for our youngest and most vulnerable population. Thank you!

17. I oppose this policy ” Inclusion of Children with Disabilities in Early Childhood Programs” for Deaf and Hard of Hearing children. I supports the need for a continuum of services for the Deaf and Hard of Hearing children because the children vary in their communication and language abilities.
    Please do not push full-inclusion policy upon deaf children without consulting with professionals working with Deaf and Hard of Hearing children to access what is best for each individual child.

18. I was fortunate to have the opportunity for my son, who is a typically developing child to attend a child care center that inclusion classes. Just by being at the center whether he was in the inclusion class or not, he benifitted from a model that provided for a master level teacher on site, art programs, and other aspect that created a high quality program with early detection of development delays for all children. And having the early diagnosis creates better chances for helping the child and family.

    I chose to go this particular program because of a friend who’s son was enrolled and benefitted from being diaganos early by a staff person at the center

19. As a deaf person and life long educator who completed a dissertation on the IDEA and critical factors in educational placements of Deaf and Hard of Hearing (D/HH) students, I find the proposed policy lacking for the following reasons:

    • The most important principle of the IDEA is that placements, programs and services are based on the individual child’s abilities and needs. Not every child will benefit from the environment being advocated in this statement, and creating a one-size fits all environment is bound to have an adverse impact on students who are appropriately placed and receiving exemplary services in a variety of other settings.
    • Unless the child is appropriate placed and the programs and services being provided are appropriate, the inclusion being advocated here is really an illusion. This is especially true with Deaf/Hard of Hearing (D/HH) children whose language and communication development needs require exposure and immersion in visual language environments, often in the home and special schools where there is a critical mass of expertise available to the child and family.
    • The first three years of life are critical in terms of language and cognitive development for ALL children and there is an abundance of research demonstrating that early identification and immersion in visual and spoken languages is hugely important if a D/HH child is expected to arrive at Kindergarten level ready to learn. The typical classroom described in this policy statement will not provide the level of direct and unimpeded language immersion and access to learning needed for a typical D/HH child.
    • Like all other children, D/HH kids need an environment where there is a critical mass of like-language peers, other children who use their preferred language(s) and communication modalities. If implemented as written this policy statement will have the effect of isolating D/HH children from others who share their readily accessible language(s) and communication modalities.
    • Truth be told, “Inclusion” is not mandated by IDEA. The law requires that decisions on placements, programs and services be made on an individual basis, and that these decisions be made by qualified individuals and involve the family. The so-called inclusive setting described in this proposed policy may well be appropriate for some children, but no singular placement type is appropriate for all. The policy statement advocates a specific placement without addressing the necessary steps (e.g., IFSP/IEP), required by the IDEA, for some children a direct and dangerous affront to the law itself.
    • States are required to provide a continuum of alternative placements and only a properly executed IFSP/IEP can determine the Least Restrictive Environment for a particular child. It is far more practical and even safer to properly execute an IFSP/IEP than to risk placing a child in an environment where his/her access to language and learning is inhibited or impeded.
    • The U.S. Department of Education has stated repeatedly since 1992 that “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child.” Implementation of this policy will effectively disregard a widely acknowledged and practiced policy.

    Disabled children are protected from discrimination by several laws, including the IDEA, Section 504, and the ADA. If the real issue is compliance with existing law then the USDOE should focus its time and energy on taking corrective action to ensure that children can access the environment deemed appropriate for them on the basis of their IFSP/IEP. I recommend the Department reconsider issuance of the policy and am fearful that as currently proposed it will have the net effect of harming many children.

20. As a product of a deaf school system, I take this proposed policy statement personally. With full and direct access to education at a deaf school, together with unfiltered communication with my deaf peers, it provided me the essential tools and confidence to succeed. As a result, I now hold a law degree and a governmental management position overseeing rulemaking proceedings.

    To put this in perspective, this policy guideline is a recipe for disaster for thousands, if not millions, of future children who are deaf and hard of hearing. Although on paper, inclusion may appear to be a sensible approach which rings true to your ears for children with disabilities, I doesn’t in our eyes and it is NOT for many deaf and hard of hearing children. You might as well call it “SECLUSION” because those children will become isolated due to communication barriers in an all hearing environment. Had you simply asked deaf and hard of hearing adults like myself who attended a school for the deaf, an overwhelming number of them would insist on preserving school for the deaf as an option. As a governmental decision maker and stewardship of taxpayers’ monies such as yourselves, I understand the necessity of running by the cost benefit analysis by putting a price tag on a child with a disability. The cost consequence of implementing the policy of inclusion on ALL children with disabilities, including the deaf and hard of hearing, would be insurmountable, if not cost prohibitive. Going along with this policy is not only socially and fiscally (if u put a price tag on it) irresponsible, but a total disregard to the educational, not to mention, EMOTIONAL, needs for those deaf and hard of hearing children.
    Greg and Charmaine Hlibok, Ellicott City, MD

21. please re-do this! It does not design for deaf community!

22. A follow up to my previous comments. Here’s one of my favorite quotes…

    “If you think Education is expensive, try ignorance.”

    —-Derek Bok, 25th President of Harvard University (1971-1991)

    The proposed draft to inclusive Deaf and Hard of hearing children may sound cheaper financially and resourcefully when it is ACTUALLY not the case. Without a 100% access to the primary language, American Sign Language in this case for DHH children, in early interventions, early childhood education, and public education classrooms, we are and have been preparing the majority (70%) of our DHH children to reach below-average English literacy and social skills after they graduate from High School. And having great difficulty to find employment, they end up living off on government welfares for the next 50 years.

    Think about it twice, thrice, and countless.

    Thank you.

    Michael (Mike) Baer

23. The purpose of IDEA is to address the INDIVIDUAL needs of the child. It is imperative that a continuum of placement options be available to all children to ensure they receive a free, appropriate public education. The focus of the law, as it should be, is on access to an appropriate education program for each individual child. Children who are deaf/hard of hearing who are placed in a regular education setting for the sake of “inclusion” without analysis as to if this placement is meaningful for the them are at risk for being deprived of educational, linguistic, and social/emotional opportunities. IDEA does NOT mandate inclusion; rather, it mandates a continuum of placement options that can address the individual child’s needs be available including special classes and special schools. Any placement option that appropriately addresses the needs of the individual child can be considered the Least Restrictive Environment (e.g., barrier-free access to language, direct communication with professionals and peers). The U.S. Department of Education itself has stated that if the communication and related needs of a child who is deaf are not met, that placement option is a denial of FAPE and cannot be considered the LRE. To quote the U.S. DOE, “Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.”

    Families continually face barriers to accessing unbiased, accurate information about the needs of children who are deaf/hard of hearing. This document will perpetuate and escalate that issue. Students who are deaf/hard of hearing must have access to highly qualified professionals who are trained and experienced in the field of deaf education. Specialized schools and programs for children who are deaf/hard of hearing are designed to meet those specific needs. These programs should be optimized and utilized as early as possible so the child can develop a strong foundation of language, readiness skills, academic concepts, and social competencies. These specialized schools and programs serve as the resource where families and their children can receive the support they need.

    I strongly oppose this policy statement and would encourage the U.S. Department of Education and U.S. Health and Human Services to recognize that children who are deaf/hard of hearing have unique needs that must be met in a unique way.

24. I have spent the last 20 years working as a Speech Language Pathologist with children from 16 months through 7 years old on Long Island, NY. I have acquired a deep understanding and appreciation of the fact that each child’s physical and psychological needs are, ultimately, unique to that youngster. Any proposal which fails to leave the ultimate determination as how and where to provide educational, physical and emotional services to the those who best know and understand the child’s needs, (i.e., the child’s teachers, administrators, health professionals and parents), is doomed to fail. The one size fits all approach to education has long been discredited. While the inclusion of special needs students into mainstream educational programs sounds appropriate to the public at large, those of us who have spent our professional lives servicing special needs students know different. We understand the need to have choices when it comes to services which cannot be offered in a typical school and the need for the flexibility to change a student’s program as his or her needs change, especially at such a delicate age. Forcing inclusion on a youngster with special needs without careful consideration of his or her individual needs is unsound educational policy.

25. Greetings, I am pleased to see a hefty amount of comments made by deaf community. The weight of this issue is great, however, the size of our community certainly do pale in comparison to others.

    Myself, am an product of deaf school and the opportunity to grow up in an bilingual environment, especially among our own kind was a luxury to me. The more I grow up, the more I realize how luxurious this was but this shouldn’t seem luxurious at all. Due to the scarce number of deaf students who goes to a deaf school, a place of language access and experience no different at home too. This should have been an standard for every deaf student.

    I would like to kindly remind to the people with power above us, that they are VISITORS of our culture and it is an privilege for anybody outside to be part of it. Including learning our language, understanding our customs and history behind all. It is a grave dishonor for anybody else to manhandle and force policies against our community.

    Thank you.

26. I am extremely concerned about the potentially devastating implications of the proposed policy statement, particularly as it relates to the needs of children who are deaf or hard of hearing. As many of the comments indicate, IDEA is about meeting the individual needs of each child. The Least Restrictive Environment is not necessarily the same as inclusion. Inclusion, when done well, and when the child is able to fully access the curriculum is indeed the best option for many children. However, if the goal becomes inclusion for all rather than meeting the needs of each child, the spirit of the law is lost and children are harmed. As Judith Vreeland commented above, “For deaf children the most critical factor in achieving their academic potential is early language development. Deaf infants and toddlers deserve specialized early intervention services and young deaf children deserve linguistically accessible preschools designed to meet their needs.” Far too many children with hearing loss are denied access to an appropriate specialized early childhood program that is taught by specialist teachers of the deaf in settings that are specifically designed and optimized for the early language learning needs of young children with hearing loss. For deaf or hard of hearing children who use cochlear implants or hearing aids to help them access and learn spoken language, placement in a specialized program during the early childhood years often allows them to be successfully included in elementary school programs–achieving at or above grade level. For these children, “inclusion” too early in a non-specialized early childhood program could permanently compromise their linguistic and academic development, and their ultimate ability to be successfully included with their hearing peers.

27. What??? NO NO you can’t shut down our school.. You can’t let hearing people who thinks that deaf is basic but that is not true… Hearing and deaf are EQUAL..

28. Thank you for providing a joint policy statement such as this. I believe this policy statement to be the “North Star” to which all states and territories should take aim. We are all at various stages of providing appropriate and meaningful inclusive settings for our youngest learners. This paper offers sound research and guidance for SEAs and LEAs with regard to high quality inclusion and where each state and territory can begin to take meaningful action. The strongest message is that this is not a Part C or 619 issue. This is an early childhood community issue and we must partner together in meeting the needs of young children with disabilities and their families. Thank you!

29. While I wholeheartedly support the concept of inclusion and integration as a way of teaching all compassion and understanding and building across differences, there is one group for whom inclusion does a disservice and that is for Deaf children who are forced to main stream into environments which are not fully accessible.
    Deaf Children need to be in educational settings where their classroom are full accessible–not only the teachers, but what their classmates are saying–so if their classmates are sitting behind them and say something, they miss it. If there is cross conversation, or dialogue, they miss it, interpreters cannot keep up (not because they are not skilled, but the pace at which it goes is nearly impossible to follow mutiple individuals). How can a Deaf child follow all of that and take notes? Moving beynd the classroom, is the hallway conversation accessible or “inclusive” to them? or the nurse? or the interscholastic teams which are not interpreted? For Deaf children being forced into a main stream environment under the label of “inclusion”, it really is only a partially inclusive, if inclusive at all–in fact it is not inclusive for them–it is including them for the sake of the other children but not for THEIR sake since they are actually being done a disservice. For them the environment is LESS THEN inclusive. Deaf students deserve the MOST ENABLING ENVIRONMENT not the least, and that is a fully language accessible environment–everywhere–so they can learn everywhere–just like every other child can–in the classrooms, from the teachers, from their peers, in the hallways, at lunch, at the nurse, on the playing fields, at recess, everywhere.
    Marja Brandon
    Head of School
    The Pennsylvania School for the Deaf

30. On behalf of the Collaboration to Promote Self-Determination (CPSD), we write to strong support the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education and commends the Departments on their collaboration and excellent policy statement.

    CPSD is a national, family-driven and consumer-led advocacy network of 20 national organizations. We focus on high-impact public policy and systems reform to improve the employment and socio-economic outcomes of citizens with intellectual and developmental disabilities promoting the effective transition of students with developmental disabilities into adulthood by preparing them to obtain optimal outcomes in education, employment, economic advancement, and independent living.

    Inclusive early childhood experiences open the doors to inclusion in kindergarten through high school and an inclusive life in the community. Conversely, barring the door to inclusive early childhood programs often enters a child into a pipeline to separate “life skills classes” in K-12 which frequently results in a life of subminimum wage in sheltered workshops or sitting home alone on a parent’s couch.

    The joint policy statement clearly identifies the scientific and legal foundations for early inclusion: it identifies potential barriers, and recommends specific, common-sense strategies for partnering to “build a nationwide culture of inclusion”. The emphasis on applying the policy “to all young children with disabilities, from those with the mildest disabilities, to those with the most significant disabilities.” is particularly important, as children with significant disabilities are often the ones denied inclusive opportunities throughout their lives.

    The policy calls for states to “Ensure that the principle of natural proportions guide the design of inclusive early childhood programs.” It further articulates that “natural proportions” means the inclusion of children with disabilities in proportion to their presence in the general population.

    Despite CPSD’s appreciation for the points above, we do believe that in order to implement this policy, it will be important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring. They are:

    • Currently an early childhood setting is counted as a regular early childhood program (inclusive) if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”.

    • At this time, if parents are unable to convince the school district to place their child in an inclusive early childhood setting, and pay themselves for their child to attend an inclusive program, the district is still given “credit” in the OSEP 618 Preschool Data Collection for the child attending an early childhood setting in an inclusive (regular education early childhood) program. This is patently unfair and needs to be changed.
    CPSD appreciates the opportunity to comment.

    Sincerely,

    Denise Marshall
    CPSD Policy Co-Chair
    Executive Director, Council of Parent Attorneys and Advocates

    Barbara Trader
    CPSD Policy Co-Chair
    Executive Director, TASH

31. Change to l0-12% disabled in a regular early childhood programs.

    OSEP data collection should distinguish between a child attending a regular education early childhood program that is provided by the district (in either a public or private setting) and one that is provided by the parents. In order to ensure transparency as to the districts role, the data collection should be changed to reflect the important distinction.

    Our grandson who is Down Syndrome was going to be put in an early intervention program that began at noon. Right after lunch he always was tired. It was not a good time to begin a program. He was put in a local junior college inclusive regular early childhood program. Chris is now 27 years old and finished a post secondary program at Ohio State. Inclusion has always been a problem in both states that he lived. His early years were in Washington State. We appreciate the educators who helped but would like to forget those who made it difficult! Inclusion in all phases of his life made him a well rounded person. His classmates benefited as much by this experience!

    Carol Gray
    Former Preschool for Head Start and Private Preschool for a Retirement Center and Advocate for NDSC MOST OF ALL A GRANDMOTHER

32. The United State Department of Education (USDOE) draft statement on inclusion in early childhood programs highlights the importance of preschool education for children to succeed in the 21st century. Preschool education produces consistent gains on achievement test scores, with a reduction of grade retention and placement in special education classrooms. A 2013 report on state-funded preschool in New Jersey (Abbott Preschool Program Longitudinal Effects Study – APPLES) showed that by 4th or 5th grade these children were, on average:

    1. Three quarters of an academic year ahead of students who did not attend quality preschool;
    2. Made significant academic gains in language arts, literacy math and science; and
    3. Were less likely to be retained a grade or require special education.

    Children from low-income families have the most to gain and preschool helps these young students acquire necessary academic and social skills.

    Many students with disabilities take part in New Jersey’s public preschool, private provider and Head Start classrooms. New Jersey offers a wide variety of placement options for children with more complex needs, including state-approved private schools for students with disabilities. Many of the preschoolers enrolled in private special education schools who receive specialized services return to their home districts in preschool, kindergarten, and the early grades. An exit study conducted by ASAH showed that, in 2013-14, 85 percent of the preschool students enrolled in private schools returned to in-district programs, with 54 percent placed in regular classrooms. The special, intensive, therapeutic care offered by private schools make a huge impact on outcomes for these young children.

    IDEA requires that states make available a full continuum of placement options for children 3-21. Special education – and education in general – should not be seen as a place but an integrated pathway for students to obtain the individualized instruction and supplemental services needed to be successful. For some children (both special education and general education) the least restrictive environment may not be a classroom in the home district, but rather a specialized program tailored to that student’s particular interests and needs – such as a charter school, alternative school, private school, vocational program, or home instruction. Decision-making should be individualized and based on identified needs.

    We agree that there must be opportunities for children with disabilities to take part in programs with non-disabled peers. However, federal law requires the full continuum of options – not full inclusion. IDEA does not use the term “inclusion” but wisely structures a decision-making process for those who know the child to make an individual decision. The law requires placement not only in the LRE but also the provision of services that are “appropriate”. Placement in a generic early childhood program may not be appropriate for every child and the position paper suggests that specialized programs are not acceptable. This does a disservice to the 40 year history of IDEA and the thousands of public and private school educators who have provided highly specialized services to preschoolers, enabling them to lead happy, productive lives.

    This policy suggests a “one size fits all” model and does not support the rights of students and parents who are promised that a continuum of services be available as necessary to truly meet the needs of individuals with disabilities.

    It is inappropriate for the US Department of Education to set policy that substitutes its philosophy for current law. IDEA is well written and carefully crafted by Congress. It needs to be accurately implemented to ensure that ALL students with disabilities continue to be served appropriately.

33. I am a proud Deaf individual and a father of a developmentally disabled son. Yes, I do support the idea of an inclusion for my son however I am NOT in favor of the “Inclusion of Children with Disabilities in the Early Childhood Programs”. Like the others have mentioned above, it is not one size fits all. I spend my childhood education by attending 13 different schools:
    – speech and hearing centers
    – private catholic school for the deaf
    – public school with resource classroom
    – public school without support services
    – public school with support services
    – residential school for the deaf
    The only school that I REALLY learned was a residential school for the deaf during my last 3 years of High School. The whole new world opened me up when I learned American Sign Language and faced NO communication restrictions/barriers at my High School. Residential schools for the deaf is a language rich environment (LRE). The adults in the policy making group need to understand that the Deaf children are a linguistic minority and it is imperative for the educational system to meet the Deaf child’s communication needs, NOT making a Deaf child to meet the school’s communication needs. Remember, it takes a village to raise a Deaf child without any communication barriers and/or isolation. Residential schools for the Deaf should not be considered a segregated school but a boarding school that is a part of the parent’s option of the educational continuum.

34. I appreciate the ideal of inclusion, having students from a variety of backgrounds together in one classroom, learning from each other, and growing up to become more well-rounded adults. However, for many students with disabilities they will not be able to talk with their peers if they are deaf, they will not be able to run around the playground if they are paraplegic, they will not be able to see what the teacher is explaining on the white board if they are blind, and the list goes on. I am a teacher of the Deaf and I have a master’s degree in Education of the Deaf and Hard-of-Hearing. I studied for 5 ½ years learning how to teach students who are Deaf and hard-of-hearing. General education teachers do not have this kind of training, and it causes unneeded stress on both faculty and students when there is a language barrier that cannot be crossed in a short period of time. True American Sign Language (ASL) can take years to master, just like any foreign language. ASL is not another form of English. It is a language in its own right. If the teacher is unable to communicate with the student they are serving, there is no possible way “meaningful inclusion in high-quality early childhood programs” can occur. In order for content to be meaningful, you must be able to participate in the conversation. As stated in the DRAFT POLICY STATEMENT overview, “It is well documented that the beginning years of all children’s lives are critical for building the early foundations of learning and wellness needed for success in school and later in life.” I completely agree. This is the key to being prepared for school and beyond, which is why students MUST be able to communicate with their families and teachers at the earliest age possible and this can only happen when everyone is speaking the same language.

    This is an age old battle in education. It is time that when we say everyone deserves the best education we can give them it truly means EVERYONE, not only the ones who fit into the cookie cutter guidelines we have given them. For this to happen, we must have individualized programs for students with special needs. If they did not need a specialized program, we would not say that they have specialized needs. Giving them the highest quality we can give them would be making sure that they have a teacher who is certified to teach their area of need. There is no possible way we as teachers can be experts in every type of disability and every type of special need. We have specialized degrees for a reason, and that is to the benefit of our students.

35. The majority of my 30 years of professional experience has been spent providing direct services to children who are Deaf or Hard-of-Hearing and their families. While I firmly believe that American Sign Language (ASL) is a full, rich language, like any other, and view it as the cornerstone of American Deaf culture, I do not agree with the notion that infants and toddlers who are Deaf or Hard-of-Hearing are necessarily members of that culture. Here’s why:

    (1) Culture is a learned set of values and behaviors passed on by one generation to the next;
    (2) Culture is comprised, among other things, of the milieu into which one is introduced early on in life or the milieu into which one immerses oneself as a part of the developmental process across the lifespan;
    (3) American Deaf culture is a viable, authentic, desirable option for many children who are Deaf or Hard-of-Hearing; however, it may or may not be the culture into which a child is born (or adopted).
    (4) Culture is derived from interaction with one’s primary caregivers (e.g., parents, siblings, extended family) as well as important fellow community members;
    (5) That being said, the dominion of the family is sacrosanct; the family’s choices with regard to cultural alignment are inviolable; to suggest otherwise is pretension and demeaning;
    (6) Early intervention services are intended to support families in recognizing what works and what doesn’t within the context of their family, not to supersede or undermine their decisions; it is not an early interventionist’s place to decide for a family or bring to the table expectations for the family, but rather to support a family’s ability to make carefully thought out, well-informed decisions;
    (7) I believe that being Deaf or Hard-of-Hearing is no more a disability than any other difference of ability that impacts one’s life (e.g., physical, intellectual, sensory, behavioral, emotional differences); however, it can and frequently does significantly impacts communication development;
    (8) Families are the only ones entitled to chose on behalf of their children whether or not to utilize an alternative or augmentative communication system (e.g., ASL);
    (9) Early intervention workers can and should support a family’s ability to consider such an option but should NEVER approach a family with preconceived notions or hidden agendas;
    (10) Research supports the idea that the use of signed language is in no way an impediment to the development of spoken language; therefore, our energies should be focused on eliminating misconceptions and misinformation about signed language rather than forcing families to make a choice between spoken and signed language;
    (11) It is imperative that early intervention workers recognize their own biases and respect and support the choices of families; and finally
    (12) It is not our job to “rescue” children from the choices of their families, but rather to provide families with the best available evidence to inform their decision-making processes.

36. I am very pro inclusion in general, but as many other commenters have stated, it may not be the best practice in every situation. More importantly, proximity does not equal inclusion. Just placing a child with disabilities in a classroom with non-disabled peers does not offer any benefits without necessary supports to allow them to access their education. I would hope that any inclusion policy would be written so as to allow the IEP team to make decisions that make the most sense for the child.

37. This statement goes a very long way in expelling one of the key barriers to inclusion: attitudes and beliefs. With an eye toward the extensive research that has been conducted over the years on inclusion, the document highlights the importance of high quality inclusion for young children with disabilities. It goes a long way toward identifying the methods and processes that support quality inclusion ensuring long- term positive outcomes all children. Your work is commended.

38. The majority of students with disabilities are best supported in regular education classrooms. However, a policy such as proposed on full inclusion is not in line with law and regulation, and takes the placement decision from the parents and professionals comprising the IEP/IFSP teams. This proposed policy would remove options on the continuum for students who are most appropriately served in these settings, and give the decision making authority to the Department of Education on what is “best” for students.

39. As a parent of a child with Down syndrome, I encourage you to support the policy statement from the U.S. Department of Education on inclusion. Our children learn from others and inclusive practices have been shown time and again to be best practices.

40. • “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

    • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.

    • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

    • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

    • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

    • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

    • Thank for for the opportunity to comment on this important policy issue. Two points: we should be talking about ; “Blended” programs which have been described in a recent monograph published by the Division for Early Childhood of the Council of Exceptional Children. Blended programs are conceived with the needs and interests of ALL children in mind with a Multi-tiered System of Support (like Response to Intetvention) so Recommended and Evidence Based practices including data-based decision making are in place. See Prairie Children Preschool in Aurora illinois. Virtual school on the RTI Action Network. Second point: stop talking about “high quality preschool”. That refers to inputs. We need to promote effective and efficient programmatic, instructional and curricular decisions that lead to student attainment of strong outcomes on measures that meet standards of technical adequacy like Individual Growth and Development Indicators (University of Minnesota, Scott McConnell, Robin Hojnoski). If we could have children enrolled in effective and efficient blended programs we would make huge strides forward. Thank you!

    • I agree that this policy statement creates confusion and disregards factors that must be considered in determining placement for a deaf or hard of hearing child. For true “inclusion”, a young child must be in an environment where he or she communicates directly and fluently with staff and peers. For a child whose natural language is accessed visually, that means with teachers and students fluent in American Sign Language.

    • Hello there,
      As a proud hearing mom of a beautiful Deaf child who is in the Early Childhood Education system at a Deaf School,
      I want to state that when any hearing educated person decides to decide for the DEAF children,
      Ijust wish,that hearing person could just spend 1full day at a Deaf School and experience the educational process of full language and communication access for the DEAF children.
      I am100percent sure that it will be an enlightened experience.
      Imagine all the hearing and deaf kids in the same class room setup and not having full language access by which I mean American Sign Language.
      Can you as the decision maker on Deaf children, live with not allowing them full access to their natural environment and language.
      Also, let’s try to switch all the hearing kids in a Deaf School for a day with no access to oral communication and see if they can thrive in that setting.
      In this case,are we not depriving the hearing kids full language access?
      I as a parent do not see why it’s so difficult to understand how access deprived will the deaf kids be if they are not allowed to thrive with their visual language in a natural deaf setup.
      Research based decision making is not always100percent but experience based decision making is always 100percent a chance of doing the right thing. Who better can decide for the DEAF than the Deaf themselves when it comes to any Inclusiveness Policies for the DEAF children.
      I strongly recommend that only the DEAF can make better choices for the DEAF Community and children because none of the hearing community can even ever imagine and experience what it means to be DEAF and grow up Deaf in the hearing world.

    • Agreed! You hit the nail on the head Steve Saenz!

    • Steve Saenz says it best.

      Why is this policy statement needed? Children should already be receiving high quality education regardless of the program they are enrolled in.

      IDEA, ADA and Section 504 of the Rehabilitation Act provides for the early childhood programs.

      Get rid of this policy that misinterprets the law and causes confusion.

      Inclusion is not for everyone. I should know. As a deaf person, I’ve experience an “inclusion” program and can share that it is not for everyone.

      Inclusion does not provide for the different learning styles. When this happens, many children fail. The sad part is in the right educational environment, children do not have to “catch up”. Catching up happens to too many deaf, hard of hearing, and deaf-blind children. Provided the right environment, their educational development is on level or close to it.

      For many of us Inclusion is the Most Restrictive Environment. If there are any changes, we should change Least Restrictive Environment to Language Rich Environment!

    • As the President of the Cerebral Palsy and Deaf, I agreed many comments that it does not fit all to the deaf children with cerebral palsy either. The IDEA and Section 504 of the Vocational Rehabilitation Act of 1973 only says FAPE and LRE. There is no statement in both laws about inclusion.
      Those children requires more needs to be served – language development including American Sign Language and physical development that may require more time than regular deaf children in classrooms. Also needs to be in a social where sign language involved as considering a LRE, unlike what some hearing children with disabilities can socialize with non-disabled children.
      The Cerebral Palsy and Deaf Organization opposes the Inclusion draft.

      Think about this? Thanks.

41. To whom it may concern:

    I respectively disagree with the Departments’ policy statement on inclusion of young children with disabilities in typical early childhood programs.

    As multiple individuals have already stated, IDEA requires focus on the individual child. Decisions are to be made on an individual basis after following the necessary steps (assessment, determination of needs and goals, and discussion of necessary services) to determine appropriate placement. The proposed definition of inclusion disregards these factors when the assumption is made that being in the typical early childhood classroom is meaningful for all children.

    While IDEA does not mandate “inclusion,” it does mandate that a continuum of alternative placements be offered in order to provide a free appropriate public education in the least restrictive environment (LRE). Unfortunately, IDEA presumes that the first placement option should be the regular classroom the child would attend if he or she did not have disability– regardless of how meaningful (or not) that placement is for the child. D/HH children are continually placed in non-meaningful inclusive settings because decision makers fail to consider that complete access to language (visual or spoken) is necessary in order for any activity to be meaningful.

    Children who are deaf/hard of hearing (d/hh) and their families continue to face significant barriers to accessing high-quality early intervention and early childhood programs. From the beginning, families are rarely given complete and unbiased information about the importance that complete access to language has on their children’s present and future development. A statement such as the one being proposed would only make it more difficult for families to get the accurate information, support, and education for their children when they need it most.

    For these reasons, and the many more that have already been articulately stated, I do not support the Departments’ policy statement on inclusion of young children with disabilities in typical early childhood programs. Additionally, I would like to request that the Departments actually consider a separate policy statement for the education of d/hh children.

    Sincerely,
    Angie Walker

42. We applaud the Departments’ vision for increased access for all children to inclusive, high-quality, early childhood programs. High-quality early learning opportunities set the stage for long-term educational success and quality of life. Children with disabilities and their families deserve equal access to these programs and the benefits that they offer.
    In consideration of the proposed policy statement, we offer the following recommendations:

    Given that all child and family situations are unique, states and programs must have the flexibility to develop individualized family service plans which are coordinated within the contexts of children’s abilities and families’ characteristics. For children who are blind or visually impaired, the best practices for family-centered services are described in the position paper from the Council for Exceptional Children’s Division on Visual Impairments and Deafblindness (CEC DVIDB), “Family-Centered Practices for Infants and Young Children with Visual Impairments” (Hatton et al., 2003). We encourage the Departments to ensure that all early childhood policy statements uphold and support these best practices, including in situations where families and professionals determine that intensive services in a child’s home or in a specialized setting are necessary. Such services and environments, often incorporated as a supplement or addition to inclusive programs, can provide a child and his/her family with the foundational skills which will enable him/her to learn and thrive with peers in inclusive settings. From Hatton et al., “IDEA [Individuals with Disabilities Education Act] guidelines specify that the rationale for providing supports and services in settings other than those with nondisabled peers must be described in the IFSP, suggesting that there are instances in which the early intervention team may determine that specialized settings may be appropriate. Because of the unique needs of children with visual impairments and their families, it is important that an array of service and support options be provided” (p.3)

    For a child who is blind or visually impaired, an inclusive educational environment will be most beneficial when his/her educational team includes and is supported by a qualified teacher of students with visual impairments. Often, students and families will also need support from an orientation and mobility specialist, and students who are deafblind should be supported by a deafblind specialist and intervenor, as determined by individualized evaluation and a multidisciplinary team. As Hatton and co-authors describe, “Children with visual impairments have access to efficient learning about the world only when primary caregivers, family members, and professionals consciously and consistently provide experiences that make maximum use of all senses. For most children with visual impairments, systematic learning does not occur incidentally or spontaneously” (p. 3). The competencies for service providers working with children with visual impairments are further described in the CEC DVIDB’s position paper. We strongly encourage the Departments to emphasize the importance of qualified professionals from the field of visual impairments to support children, families, and staff in all settings which include children who are blind or visually impaired.

    Again, we express our appreciation that the Departments have raised awareness of the need for expanded, more inclusive, high-quality early childhood programs. We hope that finalized language in the policy statement will encompass the need for individualized considerations of the types of supports, programs, and environments which will best serve students with disabilities and their families. In considering appropriate services for students who are blind or visually impaired, federal and state support should be continued and expanded to provide children and families with a continuum of opportunities to meet their needs and expand possibilities throughout their educational experiences and beyond.

    Sincerely,
    Rebecca Sheffield, Ph.D.
    Senior Policy Researcher
    American Foundation for the Blind

    Reference:
    Hatton, D., Anthony, T., Bishop, V., Gleason, D., Greeley, J. C., Miller, T., … Tompkins, C. (2003). Family-centered practices for infants and young children with visual impairments. Retrieved from Council for Exceptional Children Division on Visual Impairments and Deafblindness website http://community.cec.sped.org/dvi/resourcesportal/positionpapers

43. “If general education classrooms are to be considered Inclusive environments for Deaf children it has to mean that all hearing children need to learn ASL instead of making deaf children talk and lip read and use mediated communication”

44. I appreciate the efforts of all those who worked on this policy statement. I am the mother of a 7 year old son with Down syndrome. It has been our experience in raising our son that there is no other option but to ensure full inclusion in every aspect of his life.

    The policy statement articulates very clearly the benefits to all children for fully inclusive educational settings. It’s conclusions and recommendations to education agencies are rooted in sound research findings.

    I especially urge you to strengthen the recommendation of defining inclusion to mean that educational settings reflect natural proportions. Many institutions continue to define inclusion as 50/50 ratios.

    We elected to send our son to a private, community preschool rather than the public preschool for this very reason. Despite a good “academic” reputation, the 50/50 ratio the public preschool offered was not the fully inclusive setting we felt would maximize his ability to succeed. He thrived in the private preschool and entered kindergarten as prepared as his full peer group. Now, after completing kindergarten, he remains on track academically and socially. We firmly believe this is in no small part due to a fully inclusive educational setting every step of the way. Every child deserves the same.

    I hope this policy will be officially released soon and that it can serve as a foundation for building policies in elementary and secondary settings as well. Then, perhaps, one day, policies won’t be needed because our cultural norms will shift to seeing abilities, not disabilities; and to valuing differences and not viewing them as barriers to success.

45. As a teacher of the Deaf, and as someone who grew up in a Deaf family, I am very concerned about what this policy means for the future of Deaf education. In theory, inclusion sounds great for many children with disabilities; however, it also assumes a one-size fits all approach. Unfortunately, it would have the opposite effect on the language needs and academic success of Deaf children. A school for the Deaf, where Deaf children have full access to a “Language Rich Environment” (how I like to think of LRE) is actually the “Least Restrictive Environment” for them. I am also concerned that the American Speech-Language Hearing Association is the only hearing-related association that is identified with having resources to support inclusion for children. While SLPs can be a good resource, it should not be the only resource for students with hearing loss. The Laurent Clerc National Deaf Education Center should be included as a valuable resource for the education of Deaf children. I certainly hope the US Department of Education seriously considers the comments of qualified/experienced teachers of the Deaf and members of the Deaf community, as they consider their policy statement on including Deaf children in early education programs.

46. I’m a parent of two deaf children and I was a member of the Utah Schools for the Deaf and the Blind (USDB) Legislative Workgroup to update the Utah Code that regulated USDB. The new House Bill 296 was enacted in 2009. Sufficient to say, this bill alleviated concerns about, and provides solutions for, major issues such as administration structure, placement and eligibility that USDB faced at that time. The portion on eligibility was able to help raise academic expectations by providing students full access to core curriculum and lift school placement restrictions by focusing on communication and language-driven educational options. In addition, the HB 296 assured that USDB was the appropriate educational placement for services in Utah where it will allow USDB to become available to provide expertise regarding language and communication development as well as to provide a rich communication environment in school.

    With the HB 296, USDB deaf, blind and deaf-blind students are given options: Individualized Education Plan (Establish academic/services goals for those students who are not on-level) or Section 504 (Those who are on-level need direct communication and instruction with teachers and peers in ASL).

    The purpose of HB 296 was to meet the full continuum of alternative placements in order to meet the deaf child’s communication needs, linguistic needs, and social, personal and cultural needs through IEP as required by IDEA that was re-authorized in 2004 (The old Utah Code promoted mainstreaming). That being said, special classes and special schools are included in the continuum of alternative placements.

    My children have benefited academically, cognitively and socially where they have direct communication and instruction in American Sign Language from Jean Massieu School of the Deaf (JMS), under the wing of USDB. If it was not for JMS, my children may not survive in a mainstreamed setting with inadequate services/resources and limited social/communication opportunity. They may also experience isolation and language deprivation. Hence, the policy statement is not needed. Moreover, the word “inclusion” is not anywhere in the law. Section 504 and ADA are sufficient. Leave the IDEA alone as it already recognizes the continuum of education placement options.

    Thank you,
    Jodi Becker Kinner

47. As the mother of Sarah, a 13 year old with Down syndrome and a professional educator working as an Education Outreach Specialist for the Long Island Parent Center, I whole heartedly support the Policy Statement and hope to be included on the State-Level Interagency Task Force and Plan for Inclusion. During Sarah’s time in Early Intervention, Nassau County DOH worked with me and my family to put together an IFSP plan that enabled Sarah to receive services both at home and in the community. This enabled her to transition to CPSE in a neighborhood preschool with appropriate supports and services.

    Her successful integration in preschool enabled Sarah to transition as an inclusion student in her home based elementary school rather than attend a more restrictive program in another elementary school in our district separated from her siblings and neighborhood friends. This September, Sarah will transition into high school with a blended program of half-day self-contained courses to continue to focus on learning fundamental academics and be included the other half of the day as an inclusion student in general education electives. In these classes she will have the opportunity to learn alongside typical peers and work on the Universal Foundation 3A Skills. I am confident that when Sarah exists high school she will be an active self-advocate in making post secondary education and career decisions.

    These experiences aided my transition from a high school social studies teacher to a consultant educator working on grant funded programs to help people with disabilities access inclusive education, employment and community living. I enthusiastically support this policy and hope to be able to work with the Department of Education in overcoming the challenges to inclusion by supporting families and professionals in building a culture of inclusion.

48. As the president of the Florida Coalition for Spoken Language Choices and the parent of a deaf child, I fully support high quality inclusion for the majority of deaf and hard of hearing children.
    90% of deaf children are born to hearing families and those families are overwhelmingly choosing access to sound through hearing aids and cochlear implants along with listening and spoken language. When appropriate, high quality interventions such as specialized LSL/OPTIONS schools are given in a timely manner, these children are mainstreaming in preschool and kindergarten with age appropriate receptive and expressive language, without the use of ASL.
    My own son entered a mainstream classroom in first grade, without need for an interpreter. He listens, speaks, reads, and writes on grade level. He interacts with hearing peers and teachers throughout the day using listening and speaking. Meaningful inclusion environments have been crucial to his linguistic, social/emotional, and educational development since infancy.
    There will always be deaf individuals who will need and benefit from visual languages like ASL or cued speech. Communities of visual communicators are important in those cases. However, even deaf individuals who communicate visually should have maximum access to public venues, situations, and education. They have a right to meaningful inclusion in all of society including public education.

49. I oppose this policy ” Inclusion of Children with Disabilities in Early Childhood Programs” for Deaf and Hard of Hearing children. I supports the need for a continuum of services for the Deaf and Hard of Hearing children because the children vary in their communication and language abilities.
    Please do not push full-inclusion policy upon deaf children without consulting with professionals working with Deaf and Hard of Hearing children to access what is best for each individual child.

50. “Language matters” as it shapes one’s thinking and attitudes which are manifesting as behavior. Many of the concepts described in these policy statements come with a plethora of preconceived notions and subtle nuance that perpetual the idea that individuals with difference are somehow not a natural part of society when, in fact, everyone is different in some way. However, some differences impact a person’s ability to grow, development, form relationships, and learn in ways that set them apart from the societal norm. This is not a bad thing; it is simply reality. Physical, intellectual, communicative, sensory, behavioral, independence, relational, and emotional differences are just that–differences. These characteristics are only labeled as “disabilities” because we, as a society, view them that way. Person-first language may seem to be of minor importance, but person-first thinking, attitudes, and behavior are certainly not. The use of such language serves as a constant reminder that we all deserve a place at the table regardless of the idiosyncrasies we each bring with us. Strength-based language would also go a long way toward shaping thinking, attitudes, and behavior that recognize this concept. Rather than “a disabled child,” we now say, “a child with a disability,” but imagine the shift if we were to say, “a child with sensory differences” or “a child with differences of cognition” or “a child with difference of physical development.” Reframing the discussion to focus on DEGREES of ability rather than ability vs. DIS-ability reinforces strength-based thinking, attitudes, and behavior. We all have something we are not the best at, but that should not diminish the value of what we can do. “Children with differing abilities” are not second-class citizens as we continue to view “children with disabilities.” A disability is not a “bad thing”; it’s just a different way of being. Reconsidering our language will support changes in our thinking, attitudes, and behavior, and promote equal access for all individuals. “Inclusion” is a way of soft-pedaling “integration,” which implies that “segregation” is the order of the day. A very wise mother once told me, “Children with differing abilities don’t need to be ‘included’; they’re already here. Our thinking, attitudes, and behavior need to shift in order to recognize that fact.”

51. I applaud the US DOE and US DHHS collaborative effort in drafting a policy statement on inclusion. Collaborative work among entities focused on improved outcomes for all young children must continue, and this policy statement will serve as a foundational focus. I support this policy statement and the opportunities for children with disabilities to be included in early childhood programs. I do believe the “Individualized” component of the IEP and IFSP is important as teams determine the appropriate least restrictive environment for each child with a disability. I also support the concept of “natural proportions” for the inclusion of children with disabilities in early childhood programs. Having worked in both a 6/6 inclusion program and natural proportion-based program, I witnessed greater benefit to all children within the natural proportion-based program. However, what was most important for the success of the natural proportion-based program, was the preparation, training and on-going support of the early childhood special educators, early childhood education and care providers, program administrators, and families involved in these inclusive programs. There must be time and effort placed on training and support in order for inclusion to be effective and successful. Thank you for the opportunity to comment and I look forward to the next steps that emerge from this policy statement to improve opportunities for all young children.

52. While noble in purpose, the proposed ED policy on inclusion ignores the wide spectrum of human ability and where we are on our march to full participation and equality as people with disabilities.

    Choice is not choice if government removes all the options from which to choose. I’d rather see students with disabilities thriving academically wherever that educational place of their choosing may be, rather than be forced into inclusive settings which cannot serve their best interests or begin to meet their basic human needs. How wrong it would be to foist upon this wonderful generation of students with disabilities an edict that forces them into an educational institution that cannot meet their needs or assist them in developing to their fullest potential as all children deserve.

    One size does not fit the entire population of people with disabilities. The time has not arrived to do more harm to today’s and tomorrow’s students with significant disabilities in the blessed name of inclusion.

    I respectfully object to this ‘all or none’ proposed policy of the US Department of Education.

    John D. Kemp

53. Michael Baer
    Parent of 4 Deaf children attending California School for the Deaf
    Member, Community Advisory Committee, CSD-Fremont

    To U.S. Department of Education and U.S. Department of Health and Human Services,

    As a Father of four (4) pre-lingually Deaf children, I’m once again dismayed to see and learn that the Deaf Children and the Deaf Education were excluded in your draft policy statement. This oversight and occurrence, repetitively, by the Federal Government (USDE, USDHH) and State government (California State Department of Education and others) are totally inexcusable. While it is the fact that the Deaf Children is a low incidence population, nonetheless, it is still YOUR utmost civic duty and responsibility to ensure that every and single child, including every and single Deaf child, is best met, developed, and educated as we prepare them to become a productive and contributing U.S. citizens and taxpayers.

    Today is Year 2015. What is the core issue? The core issue all prominent Deaf Educators and prominent National civic organizations i.e. CESAD, ADSC, and NAD have battled for? The core issue as shown and proven scientifically from research??

    The Deaf children’s primary language taught and utilized in the acquisition and development of English literacy.

    Today, approximately 92% of Special Education children who are Deaf are taught in English-based language only whereas only 8% of Deaf children are taught in both languages English and American Sign Language (ASL).

    This is a complete and total contradiction to numerous scientific researches relating to Deaf children’s language and cognitive development for the past 25 years. The researches have shown and proved that the Deaf children and Deaf adults are the visual learners, not the auditory learners amongst hearing children and adults. Therefore ASL (the fourth largest language in America) is the visual language of the Deaf whereas English as the main language in America is the auditory (spoken) language of the Hearing.
    In addition, there are numerous researches in languages and bilingualism that show and prove that children and adults can and do master English as his/her second language through his/her primary language i.e. Spanish, French, German). after acquiring and speak his/her primary language. This is not any different for Deaf children who can and will master English literacy through ASL.

    Education and language mastery determines every individual’s employment and socioeconomic status in life. Given the English only language for a large majority of Deaf children, the sad fact is that approximately 70% of Deaf adults are unemployed primary due to below average Education and English literacy skills.

    To me, this continues to be the greatest and saddest irony in the field of Deaf Education and approximately 28 million Deaf people today. Moreover, all of the U.S. education laws, policies, and codes have been decided by a very small circle of hearing educators with almost zero input or decision making from the deaf educators and parents. Hence all of the cries and reminders from our Deaf Educators, leaders, and parents like myself to you today.

    Your report, as well as California’s Statewide Special Education Task Force report, to inclusive ALL Special Education children in regular public schools education did not address or recognize the language acquisition and development methodology for Deaf children if and when they along with Special Education children will be 100% inclusive in regular public education and classrooms. This deeply concerns me and this will be a dying breed of Deaf language and culture once and when the inclusiveness becomes a reality.

    As a member of CSD-Fremont Community Advisory Committee to the Superintendent, I share (and please read, with a deep and heavy heart) our response to California’s Statewide Special Education Task Force report. Our response is publically posted at San Mateo County Office of Education website.

    http://www.smcoe.org/assets/files/about-smcoe/superintendents-office/statewide-special-education-task-force/CallToActionDHH.pdf

    I believe all of our concerns and suggestions to the California Statewide Special Education Task force support my concerns above.

    Again we are in Year 2015. Deaf Education continues to be ignored or overlooked in Education and/or Special Education drafts, codes, reports, and recommendations. Allow me to remind you that approximately 92% of Special Education children who are Deaf are taught in English only which, in my theory, contributes to approximately 70% unemployment rate amongst Deaf adults; the rate the U.S. Department of Education and Department of Health and Human Services should not be reminded and proud of.

    According to scientific researches on languages, American Sign Language is the primary language of Deaf children.

    Lastly, read with an open-minded on all other comments posted here. From Deaf Educators / Superintendents, bilingualism educators, leaders, and parents, you are reminded on the current Federal laws i.e. Individual with Disabilities Education Act (IDEA), Free Access Public Education (FAPE), American with Disabilities Act (ADA) of 1990, and Section 504 of Rehabilitation Act of 1973) that concerns the Deaf Education and the Deaf children. And that your proposed policy statement is totally irrelevant and unnecessary as it relates to Deaf Education. Listen to us, the Deaf educators and adults who have had survived in the English only in the America public education, we are the one who knows what is the best and right education for our bright, livable and normal Deaf children.

    Thank you.

    Michael Baer
    mikebaer8@gmail.com
    Fremont, California

54. Allow me to share my personal experience where I had spent 36 hours at the special early childhood education program at the public school few years ago, I had the opportunity to observe and work with several children who had disabilities. One of them was deaf with an additional disability. The early childhood teacher had no background experience nor any kind of specialized training in the field of Deaf education and special education. She held only the BA degree in general elementary education, and was assigned to teach preschoolers that year. The teacher literally did not know what to do with the disabled children, especially for the deaf child. I observed her focusing on her “peer-model” students (children with no disabilities) at all times, and designed her lesson plans around them. There was the specific time for the preschoolers to explore the centers, the specialists (speech language therapist, physical therapist, and others) swarmed in the classroom and worked with the children with disabilities for 20 minutes, then they all left the classroom at same time. All the disabled children had only 15 minutes left to explore the centers but they often sat and waited for someone to come over and introduce the objects/books to them. The deaf preschooler had the speech language therapy, and was always pressured to voice a sound. Every time, she voiced a sound, and was overly praised. It’s not even an intelligent speech at all. On the many days, the teacher often stood behind her deaf preschooler’s seat during the snack time while she was reading aloud from the storybooks. The deaf preschooler absolutely had no idea of what’s being happening since she didn’t know the teacher was behind her and always smiled to her peers who were looking above her head (actually, they looked at the teacher and the pictures in the storybooks). The 36 hours of my observation truly gave me the starkly frightening knowledge that there are countless grossly inappropriate placement for the deaf preschoolers across the nation. I can assume that the deaf preschooler who I observed, will not thrive much due to her lack exposure of *visual language* in her early childhood years. I beg for the specific portion in this draft bill that the deaf/hard of hearing preschoolers ought to be placed where the teachers are experts in educating the deaf/hard of hearing young children in the research-based ASL/English bilingual educational environment.

    Also, I must inform you that I’m a very proud mother of my three Deaf children who were adopted at age 3 in 2001, 2004 and 2005. They all came home from Asia countries without any language, and they were immediately enrolled in the ASL/English Bilingual Early Childhood Education center. They all thrive in both languages, the American Sign Language and English. I’m truly blessed having the most appropriate early childhood program available for my children, and I strongly beg you the people who wrote this draft bill to reconsider the portion for the population of deaf/hard of hearing children. They deserve the early childhood education with the specialized bilingual teachers. Thank you for your time reading my comment.

55. While each child is unique and unrepeatable deaf children have specific needs which if not supported will impede their educational process. Inclusion is a wonderful idea, but to include deaf children might actually exclude them from social relationships, educational advancement, and the development of a positive self image that is so necessary to succeed in life. Not every disability is the same, nor are the adjustments that need to be made the same for every disabled child.
    Inclusion might deny the rights of the deaf child to receive an adequate education.

56. I’m glad to see this policy statement going forward. Recognizing that many young children with disabilities are likely to also have special health care needs, I’d like to see more intentional bridges in the policies to connect the early childhood programs to nursing consultation when needed and to the children’s medical homes/primary care providers to improve services, care, and coordination.

57. Our daughter has Down syndrome and has been in the general education classroom of her neighborhood public school since kindergarten. It hasn’t always been easy, but the benefits far outweighed the struggles. She is now a sophomore in high school and on the cheerleading team.

    Our family strongly supports the U.S. Departments of Education and Health and Human Services for the policy statement on inclusion of young children with disabilities in early childhood programs. We would only ask that the statement be consistent in saying “high-quality early childhood programs.” As it is, that phrase alternates with “inclusive high-quality early childhood programs.” I have seen “inclusive classrooms” that are just another form of segregation, inclusive by name only.

    Looking at the big picture, I would urge the Departments to eventually move away from the term “inclusion” altogether. Since you can’t be included unless you are excluded, by continuing to use the word inclusion we perpetuate exclusion.

    One thing we must always remember is that the benefits of inclusion extend beyond the child with the disability. Show me any classroom at any grade level that would not benefit from the non-curriculum lessons of kindness, compassion, tolerance and understanding that come with interacting with people with disabilities. All society benefits from recognizing that disability is a natural part of the human condition. With advances in technology, the rise of Universal Design for Learning and the recognition that everyone learns differently, the age of the inflexible curriculum should come to an end. Special education needn’t be so “special” that it has to be separate.

58. I am a hearing parent of 3 deaf children. The inclusion of deaf or hard-of-hearing children with hearing children was a DISASTER in our family because of the inability of the teachers and hearing children to communicate with my deaf children.

    Deaf and hard-of-hearing children have special communication and linguistic needs that cannot be met in a hearing-only environment. The word “inclusion” does not appear anywhere in the IDEA law. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require that early childhood programs be made accessible to children with disabilities. This draft guidance under consideration misinterprets the law and creates confusion.

    There continues to be misunderstandings surrounding the ‘disability’ of deafness. The ‘disability’ is only linked to their unique communication needs. In a hearing environment, there is an unfair expectation that the deaf hear and speak. This is exactly their disability as seen by the majority population. Their needs cannot be met if they are expected to compensate and overcompensate for those around them who cannot communicate with them. In other words, the deaf/hard-of-hearing cannot become hearing to make it easier to put them into a hearing-only early intervention program.

    This kind of inclusion is not a ‘least restrictive environment’ for the deaf or hard-of-hearing. Please do not try to reinstate such a policy. The early intervention needs of the deaf/hard-of-hearing child has been addressed and provided for in previous laws (IDEA, ADA, Rehab Act- Section 504) and is working quite well.

59. I appreciate this document’s emphasis on providing all children with access to the least restrictive environment. Individual accommodations and levels of support can be continually evaluated and adjusted to meet a child’s specific needs within that context. Children’s IFSPs and IEPs should support rather than supplant their ability to participate in everyday activities and routines.

    While the environment that is least restrictive for one child may be different than what’s least restrictive for another (children who are deaf for example), inclusion is different than mainstreaming. It’s goal is not to get children ready to move into existing systems but rather to make programs flexible enough to meet children where they are and help them reach their potential.

    I applaud the document’s call to provide access and participation to children with severe disabilities, and agree with the comment that the rule of “natural proportion” rather than 49-51% ratios provides a far more effective way of achieving the goals of inclusive programming.

    I appreciate the document’s call to integrate therapies and special education services into quality early childhood programs rather than
    supplanting children’s access to early childhood curriculum. The “Including All Children” training materials which my team developed for teachers of children 0-5 emphasize how the CDA training requirements can be enhanced to address the needs of children with disabilities (www.schoolhousedoor.com) while still protecting the integrity of the early childhood program. They have been used successfully in early childhood programs throughout the United States and the American Virgin Islands to meet the needs of children with disabilities in a variety of natural settings

60. The National Fragile X Foundation (NFXF) is the only nonprofit representing and advocating for individuals and their families who live every day with the health impacts of Fragile X. The NFXF supports a Community Support Network (CSN) serving all 50 states which provides peer-to-peer support and information to the over 1,000,000 individuals impacted by Fragile X. The NFXF strongly supports the policy statement proposed by the Department of Education (DOED) and the Department of Health and Human Services (DHHS) which encourages the inclusion of young children with disabilities in high-quality inclusive early childhood programs. The NFXF also shares in the vision that all Americans, especially individuals living with the health consequences of Fragile X, be meaningfully included in all facets of society throughout their lives.

    The NFXF has heard countless stories from our advocates about the benefits of inclusion in early childhood programs to both children with disabilities and their typically developing peers. When children with disabilities are included, they tend to have higher levels of social play, cognitive skills, motor skills, self-help skills and speech gains as they learn through peer modeling and social interaction. This is particularly important for children living with Fragile X who learn by observing others. For typically developing children, studies and anecdotal evidence have shown that having peers with disabilities in their classroom makes them more empathetic and open-minded, and helps them develop better coping skills.

    However, the NFXF has also heard from many families who choose to have their children educated in smaller classrooms which could typically be characterized as self-contained or segregated. Often these choices are based upon a fear that general education classrooms have too many students, are too over-stimulating and are staffed by teachers who are not provided with the training or the resources to successfully and meaningfully include their child in a classroom. For all students to realize the benefits envisioned by the I.D.E.A., each of these genuine concerns must also be addressed. Successful inclusion cannot be in name only. We believe it is possible for every child, IF, all members of an IEP team are “rowing together” and IF all stakeholders commit to making the needed resources available.

    We are hopeful that Policy Statement under consideration will serve to motivate parents and educators to embrace the ideal of inclusion and we are equally hopeful that the statement will motivate policy makers to commit the necessary resources. Until then, the NFXF believes that parental choice must be prioritized, as, parents most often understand their children’s needs best.

    Based upon survey data gathered with support from the CDC’s National Center on Birth Defects and Developmental Disabilities, we know that the majority of school age children living with Fragile X today are NOT spending their school days in classrooms with their age appropriate typical peers and thus not realizing the full promise of the I.D.E.A. The myriad reasons for this include:

    a) Parental reluctance/choice
    b) School imposed placement
    c) Parental lack of resources to challenge school imposed placement
    d) School lack of resources to successfully implement inclusive placement
    e) Teacher/Administrator reluctance/fear/misunderstanding of FX or I.D.E.A.

    The NFXF applauds any steps to address these deficiencies and thanks the DOED and DHHS for this important policy statement. We eagerly await its formal release.

    Jeffrey Cohen, JD, Dir. Govt Affairs and Advocacy
    j.cohen@fragilex.org

    Tony Ferlenda, CEO
    Tony@fragilex.org

    National Fragile X Foundation / http://www.fragilex.org

61. As an educated Deaf tax-paying citizen, parent and community advocate, I find this proposed “inclusion” policy ineffective to address the pedagogical issues that deaf and hard-of-hearing children as well as children with exceptional needs face in school. I have the firsthand experience of being exposed to a variety of educational settings from preschool to postsecondary: self-contained, mainstream (along with a small group of deaf peers and being solo) and residential-like. Now I’m fortunate to know what works best for individuals like me because I was given the continuum of educational options. As a matter of fact, my education boosted when I learned and communicated in ASL-English bilingualism approach. During that time I was among peers and mentors with whom I could conveniently communicate and build a relationship of understanding and mutual respect. I’d like to say that as a result it exponentially increased my cognitive and socio-emotional abilities which in turn pushed my potential to learn and do more to get the best out of this world, between Deaf and Hearing communities.

    I believe this relates to the work of Lawrence Siegel, Esq., a lawyer specializing in educational laws and rights for deaf and hard-of-hearing children. He argues that in accordance to the 1st and 14th Amendment of the U.S. Constitution it is a human right for deaf and hard-of-hearing children to have the freedom of speech and be protected for it in the sense of being able to have full access to language and communication, receptively and expressively, in their education. It doesn’t appear that the policy your committee has drafted will comply with this constitutional mandate. Don’t you see that many of the comments posted on this blog are written by Deaf adults, parents, community leaders, educators, and professionals that work with deaf and hard-of-hearing children are deeply concerned about how this policy, as you have defined, would negatively affect many children, both deaf/hh and children with disabilities? They have the real-life experience and profound understanding, knowing the good and bad of options on the education spectrum. These folks know that, based on personal background and acquaintance with the professional and grassroots community, too often deaf and hard-of-hearing children struggle when they are placed “inclusively” with peers unlike them whose learning and socialization atmosphere is mainly aural and spoken. Apparently, this is because it is societally thought they would excel in this environment on the basis that they must strive to be like others where education is universally designed for the latter. How can you ascertain that each deaf/hh child will receive all the necessary support and services per your definition of “inclusion” when there are thousands and thousands of schools nationally struggling to deal with problems and challenges to even educate the general (and diversely growing) student populations?! One may wonder why there are home schools, charter schools, magnet schools, private and religious schools, public schools, Deaf schools, online schools, and so forth. Isn’t that what America is supposed to be all about- choices and options that we the people believe and feel are best for our communities and children? Can’t we have a continuum of education opportunities that facilitate every child’s unique learning needs and foster their healthy development in becoming intelligent and contributing members of today and future’s society?

    In addition, may I suggest that we revisit what LRE (Least Restrictive Environment) realistically means for all sorts of children? In my professional and advocacy efforts for the Deaf and Hard-of-Hearing community we have our own take on LRE which is: “Language Rich Environment.” That is, deaf and hard-of-hearing children can succeed in anything they do via natural and accessible language, like ASL and written/spoken English, let alone any other languages utilized at home and school. Even hearing children greatly benefit from learning and using bi/multi-languages and research promotes the value of them learning sign language when young to aid with communication and language development. The same goes for deaf/hh children.

    Perhaps in order to deliberate over the issues raised in the policy draft, we need to take a step back, consult with people having the real experience and right expertise on the subject. Then we along with policy-makers can better understand how to rationally apply (and revise/amend if necessary) the law such as IDEA, Section 504 and ADA to support highly feasible and workable options especially for deaf and hard-of-hearing children and many other children benefitting from such law, as long as it’s appropriately interpreted and implemented for academic and social achievement in education.

    “Inclusion” as defined in your policy won’t work, unfortunately although with a good intention. Please don’t jeopardize our future children’s education; rather, listen to us and consider our input to help improve the quality of education for these children. We’ve been there.

62. Least Restrictive Environment for Deaf and hard of Hearing Students
    Day and/or residential schools for deaf and hard of hearing constitute a critical mass of deaf and hard of hearing students and offer communication options that vary: utilization of spoken language, visually supported spoken language, signed English, American Sign Language (ASL). Formal classroom instruction, student support services, co-curricular and extra-curricular activities are offered by trained professionals who provide appropriate and equal opportunities for language acquisition and learning needs of deaf and hard of hearing students. With the benefit of direct communication staff members, who have specialized training, understand the unique strengths and challenges of their students and are equipped to focus on strategies that have been demonstrated to optimize learning for deaf and hard of hearing students.

    A school for the deaf may well be considered the least restrictive environment for a child who is deaf or hard of hearing. In a program that is completely linguistically accessible students can enjoy meaningful, direct communication with everyone they encounter, including peers, role models, instructors, counselors and related service providers. This interaction with peers in various co-curricular and extra-curricular activities, whether in advanced placement courses, career and technical educational courses, national competition programs, recess, lunch, athletic and after school programs, promotes colloquial language development, builds self-esteem and fosters positive social development.

63. Empire State Association of Deaf (ESAD – New York) oppose the concept of inclusion education settings for Deaf and Hard of Hearing children.

    By it’s definition of “inclusion” means to us that each child will be sent to mainstream class. Hence, all alone and deprived from any environmental simulation provided in mainstream environment.

    Each Deaf & Hard of Hearing child need a continuum of accommodations that fits suitable to their communication needs. It’s not one size fits all.

    1) Deaf and hard of hearing children suffer from language deprivation when they are placed with hearing children with lack of full resources to ensure language access (qualified interpreters, teachers knowledgeable about visual aspects of bilingual learners, accessible technology like captions, flashing fire alarms)- and it would be both an impossible task and an undue burden for every early intervention environment and early childhood education classroom to provide the above simply due to deaf children being both unique in their language abilities and being a low-incidence disability group.

    2) This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. Also, the word “inclusion” IS NOT ANYWHERE IN THE LAW- This draft guidance misinterprets the law and creates confusion.

    3) Deaf and blind children have unique resources in state schools and large mainstream programs that are absolutely necessary for a majority if not all of the same children due to the access to qualified professionals who are trained and experienced in working with deaf and blind children and their families. On average, a public school teacher sees a deaf child once every 7 years- so how can teachers prepare for this occurrence, much less an early childhood program which are already provided by numerous deaf-specific programs. This policy paper will destroy those hard-working schools and programs which have worked for years to build up knowledge and expertise to ensure our deaf and blind children have the best language foundation. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers.

    Thus, Empire State Association of Deaf opposes the policy draft that indicates Deaf and Hard of Hearing children needs inclusion education which they all do have different communication needs. Continuum education is highly recommended from most.

    Thank you.

    Sean Gerlis, President
    Empire State Association of Deaf
    05/22/2015

64. This policy statement is inappropriate on several levels. It clearly violates the intent and procedural safeguards set forth the IDEA and does not take into consideration the individualization of needs as defined in a student’s individual education plan. I strongly urge a more careful review of this language and a better understanding of the nature of an individual student’s special needs and recommendation for learning environment that meets those needs. It is not the same for all.

65. Thank you for setting the stage to ensure that children with disabilities have the supports and resources they need to develop and learn alongside their typically developing peers within their own community.

    As the parent of a child with a significant physical disability, I found it profoundly frustrating that the funding streams created programs that could be offered by the same organization but were segregated. I could send my child to a special education program, or a head start program or the typical program, but not one program that could blend these disparate funding streams. Why, I and other families wondered, couldn’t my child attend the local program for preschoolers in my community and receive the necessary supports there?

    I know that Inclusion, is not easy. It requires professional development opportunities that support early childhood educators to learn how to collaborate with specialists to support the adults in a child’s life (parents, caregivers, childcare providers, Nanny’s, babysitters, grandparents), to learn how to create more intentional, more frequent and often, more intensive learning opportunities that enable children with disabilities to grow and develop. Funding needs to be provided to enable early childhood educators to learn from one another across disciplines and programs.

    To ensure inclusion, and to do it well, we must also include Institutes for Higher Education in this venture. There continues to be a disconnect between research, policy, practice and what practitioners in the field know about highly effective methods for supporting infants, toddlers and preschoolers with disabilities. All early childhood educators must know how to determine what is an evidence-based practice, how does one implement said EBP, how does one measure the child’s developmental progress as a result of the utilization of that EBP, and finally what does one do if despite implementation with fidelity, the EBP does not result in sufficient progress?

    My child will always be the only child with his particular disability in his classroom, school district or community, however, that does not excuse professionals from learning how to meet his needs in a typical program for infants, toddlers or preschoolers. Rather it should be a clarion call that we must ensure that our first focus is on what resources and supports do the adults in the child’s life need to support the child’s growth and development.

    I should not have had to decide between meeting his developmental needs or meeting my family’s economic needs, because the focus of early intervention and 619 programs were at home or during narrowly defined time-frames, while the typical childcare programs were ill-equipped (their words) to meet my child’s needs.

    Perhaps, we will one day see a time when all teachers, whether early childhood focused, elementary or secondary, are prepared to meet the needs of all children regardless of their race, economic status or disability. This proposal is a start in that direction.

66. Please preserve the continuum of educational placement options. The inclusive high quality immersion may work for some but not for others. It’s not one size fits all. I’m in accordance with CEASD and APSD.

    It’s vital to include deaf/hard-of-hearing personnel as part of the team–many normal-hearing professionals do not embrace having deaf and hard of hearing professionals. Many deaf professionals have pertinent degrees so use them.

67. As an individual who was placed on the autism spectrum at the age of two, I believe that the IEP/IFSP plan should be fully individualized based on a child’s needs. I want to make it clear that I strongly agree that inclusion and acceptance are very important for members of the disability community, and there should be opportunities for integration in numerous settings. Through early intervention treatment and the care I received in a tailor-made program, I vastly improved upon my social and communicative skills, and soon after began integrated classes in the first grade. If I had been placed in an inclusionary early childhood program when I was three years old, I am not positive that my needs would have been fully tended to. I may not have been able to develop as well or as quickly as I did in my very structured, individualized program. Fortunately, my parents enrolled me in a school with a highly qualified faculty and staff who were trained to handle my myriad of needs.

    Inclusion is an ideal long-term goal, but may not be an appropriate short term one. For me, initial placement in a most restrictive setting led to full success. I have the privilege of currently attending Georgetown University, and I am not certain I would be where I am today without this initial treatment.

68. I am thrilled that this policy statement is moving forward, as it has the potential to significantly impact the quality of early childhood experiences for children with and without disabilities. One recommendation that I feel is missing in the draft, or perhaps underemphasized, is the need for collaboration between specialists and classroom teachers/child care providers to support the inclusion of children with disabilities and their IFSP/IEP goals. Often, child care providers with children with disabilities in their classrooms are left off IFSP/IEP teams, are not provided with a copy of the IFSP/IEP, and/or are not informed of children’s goals. This is a huge missed opportunity for someone who spends a large proportion of the day with the child to be able to provide opportunities for children to work towards their goals throughout routines and activities within the classroom. I suggest making this collaborative partnership more of an emphasis in the policy statement. Thank you for the opportunity to comment on this very important initiative.

69. Senator Booker,

    As the parent of a child with Autism I implore you to act on our behalf and stop the Department of Education from issuing a policy promoting inclusion for all students with disabilities.

    My son is now 14 and has not been in an inclusion setting ever in his life. He is thriving, making great progress and is very socially engaging.

    Forcing kids in to an inclusion setting when it’s not appropriate for them is unconscionable. We have a long way to go in educating typical children in empathy before we can consider inclusion as a standard.

    Regards,
    Brian Welch

70. As a former speech language pathologist and educator for 19 years, I’ll reiterate that language is a top priority during this early stage of life. We also know that during birth to five, children’s understanding of the world, their personalities and approaches to learning and living in the world take firm hold. I’d like to remind policy makers that for deaf and hard of hearing children, being mainstreamed can be extremely isolating and thus restrictive in all areas of development.

    Infants and toddlers need constant language and social stimulation. ASL is the natural and only accessible language to a deaf baby and should be made available as such. Also, a preschool child cannot learn to socialize with peers using an interpreter. A setting where a deaf child does not have natural access to language and socializing can stunt the child’s development in all areas during the most critical years of life.

    “The IDEA supports ensuring that infants and toddlers with disabilities receive services in natural environments or in settings that are typical for a same-aged infant or toddler without a disability; For children ages three through 21 services are to be provided, to the maximum extent
    appropriate, in the least restrictive environment (LRE) which includes a continuum of alternative placements and supplementary services;” (taken from U.S. DEPARTMENTS OF EDUCATION AND HEALTH AND HUMAN SERVICES DRAFT POLICY STATEMENT ON INCLUSION OF CHILDREN WITH DISABILITIES EXECUTIVE SUMMARY May 15, 2015).

    A more natural, healthy, productive setting would be a playgroup, classroom, or school with other Deaf babies and/or children and adults who use ASL to communicate. In this way, deaf children develop more fully and naturally, and are better prepared for the rigors of school when they reach kindergarten age. They also develop a stronger sense of self-identity and self-confidence which will help them in all areas of life throughout the life span.

71. First and foremost, who are members of the advisory board under the U.S. Department of Education responsible for the policy statement draft on Inclusive Programs for young children with disabilities? Were deaf educators / administrators from a national organization such as CEASD and NAD appointed to this advisory board? If not, why not?

    According to statistics compiled by the Office of Exceptional Children under the Ohio Department of Education, only about 460 interpreters are employed in the Ohio schools where 4,000 deaf / hard of hearing children attend. Most interpreters are not fluent in American Sign Language; many come from community education programs that offer ASL classes, and only a handful are ITP graduates or have earned RID or EIPA certification. Deaf students in mainstream settings that benefit little from ill-trained interpreters puts a greater risk for language deprivation and deaf students’ inability to participate fully in class discussions.

    During my 40-year teaching experience in the Ohio Public Schools, one day 20 years ago, I was invited by a Deaf Program supervisor, a graduate school friend of mine, to observe self-contained deaf classrooms in various schools in the northeastern part of Ohio. Deaf students who took part in inclusive programs did not have the cognitive ability to produce meaningful communication in class discussion activities. Same issue deaf students faced during my Counseling Internship in a Deaf Program at a public school in Fair Oaks, California.

    I do NOT support DOE’s policy statement on full inclusion of students with disabilities in the Early Education Program. Reason: language-delayed deaf, hh and deaf-blind children will NOT have this opportunity if provided with interpreters who are ill-trained to assist them in learning activities.

72. The Michigan Developmental Disabilities Council (Michigan DD Council) greatly appreciates the opportunity to post comment on the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs”. The position of the council is to support fully integrated educational settings for all children including those with disabilities. Incorporated within this position, we also support holding educational standards to the same level as children of comparable age.
    The advantages of fully inclusive education for children are tremendously supported through empirical research that examines behavioral, emotional, educational, communication, and physical abilities of children with and without a disability. Early childhood inclusion helps in far greater ways than just building a teacher-child relationship/learning platform. A child integrated with similar aged children develops social and communication skills as well as the foundation for extended learning. Recognizing that integration is extremely important in early development, it is also keenly important that integration is balanced. Placing a child in an “integrated” setting with a dominantly proportional ratio leaning towards children with disabilities is not integration; rather, it is a form of modified seclusion and should not be supported.
    The council also supports state agencies, parents, schools, and educational leaders working collectively to educate one other on the importance of fully integrated educational settings for children with disabilities. By collaboratively working as a cohesive entity, this will produce great strides in breaking down the myths of educating children with disabilities. Some of the tallest hurdles to overcome are preconditioned ideologies that children with disabilities are not able to learn in more traditional and inclusive settings. Knowing this in not the case, developing an education partnership among the aforementioned groups will increase awareness and create a cooperative force that will, one day, eliminate seclusion of any child in the educational system.
    The Michigan DD Council enthusiastically supports the recommendations included in the draft policy statement on the inclusion of children with disabilities in early childhood programs.

73. My comment comes from two views. First and foremost I am a parent of a daughter who is deaf. Second, I am a Parent Advisor in my state’s Early Intervention and Involvement Department with the school for the deaf. As I read through this draft it occurred to me that the very specialized area of the deaf and hard of hearing was not addressed. The draft addresses inclusion in a very broad and general manner. When my daughter was very young I wanted to her to attend the local school in a regular classroom. The school for the deaf staff came to her school to provide some guidance to her teachers. Every time I made a surprise visit my daughter was sitting by herself in the back of the room while the other children were involved in circle time. I withdrew her and put her in preschool for the deaf. We had to drive her 120 miles round trip. But it was worth it to see her participating in class.

    The positive thing is this is just a draft. Hopefully all the comments here regarding the deaf and hard of hearing will be taken into account before this becomes finalized.

74. I commend and strongly support this policy statement on inclusion. I concur that “all young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations.” This policy statement clearly identifies that support is for high-quality inclusion as opposed to alternatives that simply place a child with disabilities in the proximity of his/her peers without the provision of maximum supplementary aids and services as required by the IDEA.

75. My response is a culmination of a variety of experiences and roles as a Deaf person and 15 years of experience as a School Psychologist working with Deaf and hard of hearing students and their families.

    I would not be where I am today without the specialized early intervention services I received as a toddler and pre-schooler in the mid 1970’s. I attended a pre-school for deaf children in which I developed language and academic readiness skills. As we lived in a small town with limited resources, my parents drove an hour each way daily so I could attend this pre-school which was housed at a major university campus. If I was born today, my parents would be subjected to well-intended, but not deaf education trained early intervention providers and then subjected to full inclusion at the local school district’s ECSE program, with maybe an itinerant deaf educator that would see me once a week.

    Full “inclusion” of deaf and hard of hearing children alongside hearing children in early intervention and early childhood programs is a misnomer because in reality, they are fully “excluded”, as they have limited access to communication through auditory means.

    A critical mass of peers is required for typical language development. A program for deaf children is the Least Restrictive Environment for deaf children to acquire language access and academic readiness skills needed to have a successful outcome by the time they graduate from high school. Programs for deaf children are among the continuum of placement options. A continuum of options are mandated by IDEA.

    The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child.

    Placing a deaf child in a local school district’s ECSE program would be most restrictive, as they are restricted from language access to the teacher, to their peers and academic growth will be stunted.

    In my professional work, I have seen countless bright deaf and hard of hearing children obtain access to language and an accessible education far too late in their school career. Due to being limited in language and academic skills, their future options are limited without extensive academic remediation.

    Early intervention programs and early childhood programs need to ensure deaf and hard of hearing children have daily access to qualified educators of the deaf and access to deaf peers.

76. The word “inclusion” sounds like a positive concept in which no child will be left out or left behind. Being placed in a regular education early childhood program, no matter how high quality it may be, has the opposite result for many deaf and hard of hearing children. These children need access to language in order to learn… anything and everything!

    I have worked at the Pennsylvania School for the Deaf for over ten years, teaching 3 – 6 year olds. Many times I have seen children who are transferred to our school from settings where they had been the only deaf child. They had no way of understanding the other children and no way of expressing themselves to others. Their language abilities were severely delayed. I have also seen “the light go on” in these children’s eyes after they join a program with their deaf peers and staff who can communicate with them in American Sign Language. What a beautiful thing to realize that you now have a way tell other people what you want and need, and they will understand you!

    I lost my own hearing at the age of 17, and often felt isolated by language barriers in high school and college. I cannot fathom how a young child is supposed to make sense of that experience, knowing how hard it was for me, an adult with a full understanding of the English language.

    Please remember that Least Restrictive Environment can be applied to any of the school settings along the continuum, from regular education classroom to specialized school. The whole purpose of the IDEA was to ensure that each child gets what he or she needs to learn, and not everyone needs the same thing. Inclusion is not the best educational choice for every child.

77. As a teacher of the deaf, I have a first hand perspective on the needs of deaf children. I teach deaf 4th and 5th graders housed in a public school. I’ve witnessed the effects of “mainstreaming” our young deaf children in their preschool years. It results in missed opportunities for their development, reduced social interaction, and greater challenges as they progress in school.

    Students in a fully deaf preschool classroom, with a teacher fluent in sign language, have better outcomes than their mainstreamed peers. They demonstrate healthy emotional intelligence, better use of language, and perform at-or-near grade level academically. Whereas the students I am now receiving from our preschool program, who have limited access to direct instruction and reduced sign language interactions, face considerably greater challenges. Their emotional intelligence is underdeveloped, which carries serious implications for their performance in school.

    Mainstreaming our young deaf children fails to provide a least restrictive language environment. Thus, we are not attending to Maslow’s hierarchy of needs. It will take many extra years for these children to find comfort with security, order, and stability. They will be unable to reach the third stage of need, love and belonging, since their connections with their peers will be impeded by their limited communication skills. Ultimately, I fear that mainstreamed deaf children will grow up to become lonelier and less actualized adults.

78. I am a professional quality engineer, and this decision about inclusion creates a cookie-cutter approach that is fine for handling a homogenous inanimate product in a factory, but is catastrophic when it comes to handling unique children from diverse situations with varying degrees of multiple disabilities in a school. Any educational approach for the disabled MUST consider those qualities, and only THEN could a student be considered for inclusion as ONE possible approach to their education. It is the job of schools to TEACH children academic topics – not to coddle them, not to improve their self-esteem, not to make academic structures more alike. Inclusion, without regard to the nature & degree of the disability, or without considering the unique child’s abilities & support structure at home, is unacceptable as a standard approach to dealing with students with special needs. In other words, disabled students are not widgets, and must NOT be shoe-horned into some “standard” approach for their education.

79. It is such an old, old story whereby they, clueless on the area of deafness, continue to obsess on the idea that complete inclusion of deaf children under the word ‘disability’ should be interpreted as ‘least restrictive environment.’ It is NOT. Whereas other (other than deaf) children with disabilities basically have the same communication modality which is speech and hearing, deaf children have a completely separate communication modality which is sign language on which they rely upon for effective communication and, more importantly, effective learning. Deaf children would suffer the most when they are grouped with other disabled children that are relying upon speech and hearing for communication and education. Schools for the deaf continue to be the best educational placement for deaf children who will definitely and eventually become successful working, tax-paying citizens in the United States. So DON’T push full-inclusion policy upon deaf children.

80. Thank you for this well written policy statement that promotes the inclusion of all young children. I could not agree more with the sentiment of this statement. I also appreciate the breadth and depth of the research and references used throughout the document. Implementing high quality preschool inclusion is not easy. Preschool inclusion requires broad-scale efforts and changes across multiple facets of an already complicated early childhood landscape. This policy statement will hopefully be the catalyst for ensuring states, districts, and programs have the needed knowledge, resources, and supports to enact high quality preschool inclusion for all children with disabilities, including children with the most severe needs. Thank you!

81. This policy looks good on the surface, but fails to take into consideration children for whom a mainstream program may not be the Least Restrictive Environment. For some Deaf or Hard of Hearing children a mainstream program with all activities and lessons taught in oral/aural English can be very restrictive – even with an interpreter.

    Many DHH children benefit from using ASL, either as a primary form of communication or to support communication in other forms. A mainstream program does not offer these children the same opportunities to develop fluency in ASL (or English) that a program geared toward Deaf children can. For instance, imagine a lesson focusing on rhyming words – hearing children can *hear* the word endings and detect rhymes, but for a DHH child using an interpreter to access the lesson, the signs for these words (ex: dog and log) have nothing in common and do not “rhyme” in any way.

    The LRE for Deaf and HoH children must be determined individually, based on the learning and language needs of the child. For some, an integrated program poses significant restrictions on their language acquisition and social/cognitive/emotional development. They may benefit from a program designed for kids with hearing loss, where activities and language are presented visually and accessed easily, social interactions with peers/educators can be effortless, and they are given equal access to language.

    In short, IDEA was created to allow children with disabilities to access education in the manner least restrictive to their individual educational needs. For some DHH children, an inclusive mainstream classroom, even with an interpreter, can mean unequal access to language and learning and may be a very restrictive environment. Separate programs geared toward DHH education and Deaf School programs must be an option for DHH children.

    • I agree with early ed being accessable to disabled children when it makes sence. However it should not be used to exclude deaf centric options for deaf children to same age peers and early education I agree that early intervention programs and early childhood programs need to ensure deaf and hard of hearing children have daily access to qualified educators of the deaf and access to deaf peers.

82. I agree with the information included in the Executive Summary. I am a Technical Assistant and work with Itinerant Teachers. My state has been trying to increase the number of 619 programs providing services in natural environments, but has run up against many barriers. Many child cares provide high quality early childhood programs, and children identified with special needs could benefit from remaining in these settings with resources coming to them. Unfortunately, we often have the child transition out of the program to attend a district early childhood special education program for part of the day.
    Many districts believe it is fiscally responsible to have these children attend a 619 program, rather than have their teachers go out into natural environments. I think we need to analyze the financial aspects of running the district early childhood programs, including transportation, building costs, etc. and determine the difference in cost.
    Serving children in their natural environments provides many benefits to the child , family and early childhood program. First, it decreases the number of transitions the child needs to experience. When itinerant services are provided using consultation and/or coaching, all children benefit. The early childhood teacher learns new techniques, strategies, accommodations, and modifications to meet the needs of her students. This service delivery model also helps to build rapport between the school district and community settings and fosters communication. The use Technical Assistants who specialize in inclusion as part of our QRIS could also assist in children identified with special needs meeting success in an inclusive environment. When children come into schools for special education services, there is little to no communication with the child care where that student spends a good part of their day. These specialized T.A.’s could assist child cares in meeting the needs of those students.
    I support the inclusion policy statement in hopes it will provide the momentum needed to continue to move forward in this area.

83. “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

    • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.
    • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

    • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

    • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

    • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

84. Whilst I cannot speak for all disability groups, I can strongly speak for those with communication disorders, especially deafness. Here are my thoughts as an educator:

    “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

    • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.
    • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

    • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

    • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

    • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

    In other words I do not support this proposal at all.

85. Please don’t change it by policy because the children will confuse about the education and classroom. Don’t change and just leave alone them because they already develop own knowledge during school in classroom. Don’t mess up education with disabilities what they have. I myself experience and am profoundly Deaf. Keep that way. My daughter is CODA is working with special Ed /Deaf Ed teacher. Also my son in law is CODA work at deaf school. Thank you.

86. . This document appears to be OSEPS publishing a policy without any input from legislators or from people like myself in the field.

    The word “inclusion” is not even found in the Individuals with Disabilities Education Act. What is loud and clear in IDEA is the concept that a school district must maintain a continuum of “placement options” so that each child gets appropriate services. Promoting a “one size fits all” agenda is contrary to the letter and spirit of the law.

    This draft was put out this week for only a 5 day period of public comment. Doing this the week before Memorial Day at any educator’s most hectic time of year shows callous disregard for any meaningful input either from educators or legislators.

    This draft should be withdrawn.

87. The Deaf Coalition of Iowa does not agree with the inclusion of deaf and hard of hearing infants and children in this policy. We have been trying to support education that specializes in deaf and hard of hearing children in our state, but federal education guidelines usually disregard the individual deaf and hard of hearing child’s education needs. The IEP teams usually do not have any understanding of the individual child’s language, social and deaf education approaches. Instead they include special education or broad disability solutions that fail to address deaf and hard of hearing children’s learning development.

    This policy needs to be revised to address deaf and hard of hearing as a separate group. Thank you!

    • The Illinois Department of Human Services promotes empowerment rather than marginalizing a person who is deaf and does not speak or may be small in stature: among others with which whom, for and because of that drafting could be revised more towards customarily done, insomuch that they may do so gladly.

88. My son is deaf but he was mainstreamed for two year and was not provided with a licensed American Sign Language interpreter or at least a person fluent in ASL. Being the only deaf student in the school with no one to communicate with him in his language nor him being able to speak was not helpful at all. Therefore the idea that inclusion alone will indeed facilitate healthy social integration for all children regardless of personal need does not seem wise even more so with school being defunded. Please reconsider this policy of inclusion. Thank you.

89. Below is a link to the Health Recommendations referenced in my comments.

    http://www2.illinois.gov/gov/OECD/Pages/ExecutiveCommittee.aspx

    Thank you,

    Amy Zimmerman
    Director, Chicago Medical-Legal Partnership for Children

90. The role of families in Early Childhood education cannot be emphasized enough. Parents are the child’s first teachers, role model, nurse, therapist, care provider. They know this child intimately from birth.
    In the draft policy for Inclusion of Children with Disabilities in Early Childhood Programs, there is far too little emphasis on families and what they need to know regarding the legal and effective practice of inclusion for children with disabilities in early childhood programs.
    Per the Individuals with Disabilities Education Act, parents are to be informed decision makers. When children are born with a disability, there is not a package of information that comes home telling the family which doctors to use, which therapists to go to, or which effective practices will provide an appropriate and meaningful education. Parents need to receive this information as soon as possible to make decisions that will afford the child the best chance at a successful, productive and happy life.
    First, the PEAL Center would like the policy committee to consider adding training to families about the philosophy of inclusive education-one that has a good foundation for understanding the supports and services that are mandated to children with disabilities in public schools. It should also be noted that inclusivity should not be expected to be provided only in schools, but in extracurricular activities and community activities. Parents don’t know what they don’t know. To provide them this information when their children are young will ensure that families are “on board” when schools are talking about inclusive education. In order to be compliant with IDEA and ensure parents are “informed decision makers”, this information must be shared with parents at the child’s earliest age.
    Secondly, the PEAL Center would suggest information be delivered to parents whose children are entering preschool age and are moving from IFSP services to IEP services. Presently, there is too much reliance on the providers to write the plans and parents are not involved enough in the process to know what information is needed or how they can contribute needed information to their child’s team. This needs to be expressly relayed to parents.
    It is also suggested that the policy address the need for early childhood programs to use natural proportions when establishing an inclusive classroom. If we expect that our children are going to live, work and socialize in their communities, we would expect the same of their education.
    In order to move towards effective and supportive inclusive practices, parents need to understand that their full participation, in every aspect of their child’s early childhood education must include their input. They must be at the table ready with the tools they need to be informed decision makers who can explain their child’s strengths, what works for their child and most importantly, what their vision is for their child.

91. CAST thanks the Departments of Education and Heath and Human Services for this draft policy statement on the inclusion of young children with disabilities in high-quality inclusive programs. On behalf of CAST, who supports effective inclusion practices, we appreciate that Universal Design for Learning is listed as a resource in this document as we believe it is key to the design, development, and continuance of a high quality inclusion program. To that end we offer a subtle but important clarification regarding the distinction between Universal Design and Universal Design for Learning.

    In the section focused on recommendations for enhancing professional development, knowledge of Universal Design is mentioned while Universal Design for Learning is not; we think both should be mentioned. Universal Design refers to the broad spectrum of ideas that inform the development and design of accessible physical environments. Universal Design for Learning is an educational framework based on the learning sciences, including cognitive neuroscience, which informs the design and development of flexible instructional practices, materials, and tools that address the variability of all learners. Whereas Universal Design is imperative to give children with disabilities access to the physical space of an early childhood center, the Universal Design for Learning framework is essential to allow children with disabilities ways to engage with learning and to develop knowledge and skills in early childhood programs. Those who deliver high quality training to early childhood providers must understand Universal Design for Learning and how they can be implemented to ensure our most vulnerable young children have every opportunity to learn. Moreover, the Universal Design for Learning framework should be considered in the design and development of the materials and methods used to provide high quality professional development in order to address the variability that exists among adult learners and their varied contexts.

92. The Chicago Medical-Legal Partnership for Children (CMLPC) applauds the U.S. Department of Health and Human Services and the U.S. Department of Education for issuing a joint policy statement on inclusion of children with disabilities in early childhood programs, and for providing the strategies that States, LEAs, schools and early childhood programs can implement to make this vision a reality.

    The Chicago Medical-Legal Partnership for Children (CMLPC) is one of three projects at AIDS Legal Council of Chicago (soon to be renamed Legal Council for Health Justice) that joins health and hospital systems, social support services, training, expert legal assistance, and policy development to promote health and education equity across the lifespan of vulnerable populations.. We are experts in maximizing access and engagement in systems of health, education, and public benefits for at-risk populations – particularly infants and children with disabilities and special health needs – because we have specific policy and legal expertise across the complex intersections of healthcare services, early intervention, developmental therapies, child care services, educational mandates, and publicly-funded supports across federal, state, and local levels.

    The CMLPC supports each of the recommendations for State and Early Childhood Systems identified in the draft policy statement, and recognizes that it is essential that they be seen as necessary pieces of a whole. To truly ensure that our early childhood programs and services are inclusive and provide high quality experiences for each and every child, each of these recommendations must be implemented, and these issues must be seen as urgent and essential. CMLPC joins the comments in support submitted by the Ounce of Prevention.

    Increased Collaboration and Guidance at the Federal Level:
    While CMLPC agrees with the suggestion in Recommendation #2 under State Action that States “review their policies to ensure that they facilitate– rather than create barriers to- high quality inclusion,”we encourage DOE and HHS to engage in a similar exercise. DOE and HHS need to ensure that the federal laws and grant initiatives include the necessary requirements and guidance to support States and localities in being able to effectively provide increased access to high quality early childhood programs for children with disabilities. For example, CMLPC supports the suggestion in Recommendation #2 that States ensure that after children are identified with a disability, families are not forced to choose between early intervention or special education services and remaining in their existing early childhood programs. While Head Start, IDEA, and CCDBG legislation, as well as the ELC-RTT and EHS-CC partnerships, all speak to prioritizing children with disabilities, there is little focus on how programs at the local level can ensure that the necessary coordination and collaboration happens across federal funding streams to support inclusion in community based programs. It is very challenging for community based child care, Head Start/Early Head Start programs, and state funded preschool programs to provide the individualized and high quality instruction and related supports that children with disabilities need in those settings. LEAs do not necessarily provide services to children in their community based early education and care programs, and children must leave those programs for part of the day to get their services, sometimes traveling long distances. The CMLPC suggests that DOE and HHS ensure the federal laws and guidance are clear that States and LEAs are required, or at minimum, strongly encouraged, to embed special education instructional supports and related services within the community based programs. This embedded support would also go a long way in building the capacity of the community based providers.

    Develop Models of Funding:
    DOE and HHS could also consider developing some funding models and guidance that States and communities could use that illustrate how Head Start, Child Care, and IDEA funding (in addition to State and local resources) can be used to build high quality early education programs, whether they are school or community based programs. There is often confusion at the local level on how IDEA funding can be leveraged to support inclusive classrooms.

    Increased Accountability and Information at Federal Level:
    The CMLPC supports State Recommendation #3 that encourages States to set concrete goals for expanding inclusive high-quality early learning opportunities and tracking progress toward ensuring that more children are enrolled in those settings. This is another area where federal leadership could support this effort by requiring that these metrics be set and that the data be collected and shared at the national level. This data is critical to informing federal policy and investments that will promote and facilitate inclusion.

    Illinois Resources:
    Illinois, in large measure, due to the federal investment in the Race to the Top – Early Learning Challenge has embedded inclusion as an indicator of quality in its Tiered Quality Rating and Improvement System. At the highest level of quality, Illinois provides an Award of Excellence for Inclusion of Children with Special Needs to programs who show excellence in inclusion. The Award of Excellence is based on the principles in the joint DEC/NAEYC statement on inclusion. The Award and supporting resources, including Illinois’ Inclusion Guidelines, can be found at http://www.excelerateillinoisproviders.com/overview2/awards-of-excellence/inclusion-of-children-with-special-needs.

    In addition, in long recognition of importance of inclusive early childhood settings, Illinois’ State Board of Education has developed resources including an Inclusion brochure for families and professionals to better explain LRE and inclusion.
    Illinois also recently developed a new video that shows how Early Intervention services are provided in inclusive settings, and the important role that the teacher and caregiver plays in working with the Early Interventionist to support the child and family. The video can be found here: https://www.youtube.com/user/IllinoisEITraining.
    In addition to joining the Ounce comments in support, CMLPC is commenting on some additional aspects of the proposed policy. In order to insure effective inclusive settings, early childhood providers must not only be trained to understand and promote inclusion but they also should be trained to promote and support the health and well-being of children in their care. Specialized training dedicated to understanding the healthcare needs of children with chronic health conditions and the importance of such documentation as medical action plans will help ensure that early childhood providers know how to be responsive to children with special health care needs and will give parents piece of mind to enroll their children in early childhood care and education programs. The policy should include a reference to this as a training priority. Recently, a workgroup of Illinois Early Learning Council developed a comprehensive report containing recommendations related to the role of Early Care and Education providers in the health and well-being of children in their care. This report includes recommendations related to numerous health areas, including serving children with chronic health conditions.
    Additionally, all providers should be trained to understand IDEA Part B and Part C requirements in order to help advocate for families involved with or seeking access to each of these important systems. Providers are often great at making referrals but they should also be expected to advocate for children in their care to receive all supports and benefits they are eligible to receive. The policy should include a reference to this as a training priority.

    Thank you for the opportunity to provide comments on this bold joint policy statement on inclusion. The CMLPC looks forward to partnering on these issues on the federal, state and local level. We welcome any opportunity to continue this dialogue with DOE and HHS to ensure that the issues that confront States and local entities can be understood and addressed as the federal agencies continue to elevate and prioritize the urgency of inclusion of young children with disabilities, and indeed, all citizens with and without disabilities, in all facets of society.

    Sincerely,

    Amy Zimmerman
    Director, Chicago Medical-Legal Partnership for Children

93. I strongly support the US Dept of Health & Human Services policy statement on inclusion of young children with disabilities in high-quality early childhood programs. From what we now know about early brain development, this is an idea whose time has come. We also now have evidence of the benefits of young children’s interactions with early learning facilitators and their own varied and diverse age mates in developmentally appropriate groupings. We are certain that inclusion is beneficial to the children who are developing typically as well as those with special needs when they are learning together. Working with others, I have been supportive of this work on Long Island, NY through the Brookville Center for Children’s Service. They are providing high quality early care education using an inclusive model and network of centers. It has benefitted all the children and their families.

94. I agree with many of the comments, and believe that inclusion is the most important factor in servicing our youngest children with disabilities. The practice of segregating children with disabilities during their first educational experience isn’t in their best interests, and is not supported by research!
    As other comments posted point out, I am concerned that the policy does not go a step further and include language about our current practice of segregating early childhood programs by family income. In Michigan, we have two funding streams for families who are economically disadvantaged (Great Start and Head Start). These programs are typically segregated into their own classrooms. If we were to place children who receive and reduced lunch children into segregated classrooms in our K-12 system, it would be considered discrimination. Why do we allow, and promote this same kind of discrimination in Early Childhood? The policy needs to address blending of ALL funding streams, so that ALL children can attend together, as they will do when they enter kindergarten.

    Nancy Ely
    Director of Early Childhood
    Supervisor of Special Education
    Farmington Public Schools, Michigan

95. Thank you for providing the opportunity to submit comments regarding the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs.” The National Head Start Association believes that every child, regardless of circumstances at birth, has the ability to succeed in life if given the opportunity that Head Start offers to children and their families. NHSA is the national voice of more than a million children enrolled in Head Start and Early Head Start programs each year.

    In 2013-2014, about 130,000 children with either an Individualized Education Plan (IEP) or an Individualized Family Service Plan (IFSP) were served by Head Start and Early Head Start – about 12% of the children enrolled. Among them, 43.3% of children with IEPs and 37.0% of children with IFSPs were identified with a disability and began to receive services during the program year. All of these children were included with their peers in nurturing, educational settings complemented by comprehensive services including nutrition, health and dental care, and family engagement.

    NHSA wants to recognize the Departments of Education and Health and Human Services for the primary recommendation that the early childhood system partner with families and the acknowledgement that “Families are children’s first and most important teachers and the most effective advocates.” For fifty years, Head Start has been a leader in engaging families, and the families of children with disabilities are often those who benefit most from having strong relationships with program staff who understand their children’s needs and can support the whole family in accessing necessary supports.

    The challenge articulated on page 15 of the Draft Policy Statement about the misconception in some communities that early intervention should be provided in children’s homes and that preschool special education services should be delivered only in schools is a real one, and NHSA strongly supports the Departments’ clarifications that, “A mixed delivery system of public and private high-quality early childhood programs is important to increasing the availability of inclusive opportunities for children with disabilities” and that “Families should not be given an “either/or” option, such that they must choose between Head Start or special education services.”

    Many Head Start and Early Head Start programs already directly operate or collaborate with early intervention and early childhood special education programs, and we look forward to seeing their work more fully realized through engagement with the proposed state-level interagency task forces. As the National Association of State Directors of Special Education (NASDSE) has suggested in their comments below, NHSA also looks forward to being a collaborative partner in disseminating the final policy statement and the values and practices it lays out.

    Thank you once again for uniting across agencies to make this important statement about the inclusive services that best meet the needs of children with disabilities and their families. With fifty years history behind us, Head Start is committed to sharing best practices and continuing to innovate on behalf of all children.

96. I would like to echo many of the comments made thus far on statement on inclusion of young children with disabilities. I am thrilled to have the opportunity to state my full professional and personal support for the POLICY STATEMENT ON INCLUSION OF CHILDREN WITH DISABILITIES IN EARLY CHILDHOOD PROGRAMS. It frames our field’s historical values as well as current research understandings of how to support ALL of America’s children in reaching their fullest developmental potential. The policy statement supports public understanding of the research and legal foundations and provides comprehensive recommendations and resources necessary for states, LEAs and early childhood programs to implement system change. Including and supporting young children with disabilities in high quality early childhood programs is a critical first step in ensuring their future participation and positive outcomes in school and beyond. I would like to echo suggestions provided by other colleagues that would further support and clarify the policy.

    First, consider modifying the definition of early childhood programs from
    “Early childhood programs are those that provide early care and education to children birth through age five, where the majority of children in the program are typically developing. These include, but are not limited to, private or publicly funded center or family-based child care, Early Head Start, Head Start, private preschool, and public school and community-based pre-kindergarten programs.” to “Early childhood programs are those in which the primary purpose and program design is to provide high quality early care and education to all children birth through age five, including children with disabilities. These include, but are not limited to, private or publicly funded center or family-based child care, Early Head Start, Head Start, private preschool, state- and locally-funded Pre-Kindergarten programs.” In many states LEAs have created special education “integrated” preschool programs that are purposely designed to serve as the LRE for their young students with disabilities. Historically, this made sense as the quality of early care and education in their communities was poor and LEAs sought to provide a higher quality of early childhood education than could be accessed by children with disabilities and their families. However, over the past two decades, federal, state and local early childhood educators have recognized the importance of access for all children to high quality early childhood education – and its critical role when combined with effective special supports and services in supporting the learning and development of children with disabilities. This recognition has led to the development of state and local early childhood education systems that support improved early childhood education curriculum, higher early childhood teacher credentials, and data-informed instructional practices.

    The special education integrated model provides for one teacher who serves as both the general early childhood educator and special educator. It also allows LEAs to populate the classroom with up to 49% of children with disabilities. While technically inclusive, this is not the naturally occurring proportion of children with disabilities in our larger population and sets up an extraordinarily challenging, if not impossible circumstance for a teacher to support all children’s learning and development within that classroom. Current understandings of how children learn as well as what teachers need to know and be able to do, in order to provide a high quality early childhood curriculum and engage in an evidence-based instructional cycle, set very demanding practice expectations for teachers and I would argue that one teacher cannot provide all that children with and without disabilities in an integrated model require to grow and learn. My understanding is that this “integrated” model meets the federal definition of a regular early childhood program for indicator 6 data collection but does it meet the definition and the spirit of early childhood within the policy statement? Does it support high quality teaching for all children, especially children with disabilities? I propose it would be better to define the “general early childhood” environment by referencing natural proportion instead of majority.

    My second suggestion has to do with a reference in the scientific foundation section where it is stated, “…these desired outcomes are achieved only when young children with disabilities are included several days per week in social and learning opportunities with typically developing peers.” I wonder if this will lead to a literal interpretation of the number of days children need to be included as opposed to recognizing that children with disabilities require at minimal the same dosage as their peers. Finally, you may want to include Rhode Island’s Inclusive Practices tip sheet http://center-elp.org/wp-content/uploads/2015/03/Exceed-Tip-Sheet_Inclusive-Practices.pdf in your state resources. Thank you for the opportunity to provide feedback on this critical national policy!

97. I oppose this policy especially concerning deaf and hard of hearing children. Research has shown from time to time that guidelines such as IDEA and LRE to accommodate deaf and hard of hearing children’s education is steering away from improving their education. Placing deaf and hard of hearing children under a “special education” umbrella where a majority of these education experts do not understand their language development and current deaf education trends, will further harm a majority of deaf and hard of hearing children. I am concerned this is another one answer fits all misleading policy.

98. Inclusion may be a great idea or is a program that may succeed for the disability children BUT for the deaf/hard of hearing children–that is a NO NO.

99. On behalf of the Division for Early Childhood of the Council for Exceptional Children (DEC), I want to express our strong support and appreciation for the draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood programs.

    We wholeheartedly concur with the departments’ position “that all young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations.” This policy statement will be valuable to parents and other caregivers, early education and care providers, and state and local policy makers in their ongoing efforts to increase the availability of quality, inclusive education opportunities for young children and their families.

    DEC particularly appreciates your issuing this jointly from both departments, making the impact of the statement more powerful. We appreciate the policy’s definition of inclusion in early childhood programs, the legal and scientific foundations that support inclusion, and the recommendations to states, local educational agencies (LEAs), schools, and early childhood programs for expanding inclusive high-quality early learning opportunities for all children. These will be very helpful!

    DEC looks forward to the official release of this policy and will work with our members to ensure its vision becomes a reality for all children and their families. Thank you from DEC!

100. The Ounce of Prevention Fund (the Ounce) applauds the U.S. Department of Health and Human Services and the U.S. Department of Education for issuing a joint policy statement on inclusion of children with disabilities in early childhood programs, and for providing the strategies that States, LEAs, schools and early childhood programs can implement to make this vision a reality.

     Since 1982, the Ounce has persistently pursued a single goal: that all American children – particularly those born into poverty – have quality early childhood experiences in the crucial first five years of life. The Ounce gives children in poverty the best chance for success in school and in life by advocating for and providing the highest quality of care for children birth to age five. The Ounce has long maintained, as the research supports, that inclusive early childhood environments are part and parcel of providing a high quality early education and care experience for all children. The Ounce supports each of the recommendations for State and Early Childhood Systems identified in the draft policy statement, and recognizes that it is essential that they be seen as necessary pieces of a whole. To truly ensure that our early childhood programs and services are inclusive and provide high quality experiences for each and every child, each of these recommendations must be implemented, and these issues must be seen as urgent and essential.

     Increased Collaboration and Guidance at the Federal Level:
     While the Ounce agrees with the suggestion in Recommendation #2 under State Action that States “review their policies to ensure that they facilitate– rather than create barriers to- high quality inclusion”, we encourage DOE and HHS to engage in a similar exercise. DOE and HHS need to ensure that the federal laws and grant initiatives include the necessary requirements and guidance to support States and localities in being able to effectively provide increased access to high quality early childhood programs for children with disabilities.

     For example, the Ounce supports the suggestion in Recommendation #2 that States ensure that” after children are identified with a disability, families are not forced to choose between early intervention or special education services and remaining in their existing early childhood programs.” While Head Start, IDEA, and CCDBG legislation, as well as the RTT-ELC and EHS-CC partnership grants, all speak to prioritizing inclusion of children with disabilities, there is little focus at the federal level on how States, LEAs and early childhood programs can require that the necessary coordination and collaboration happens across federal funding streams to support this inclusion in community based programs. It is very challenging for community based programs to provide the individualized and high quality instruction and related supports that children with disabilities need in those settings. LEAs do not necessarily provide services to children in their community based early education and care programs, and children must leave those programs for part of the day to get their services, sometimes traveling long distances. At the same time, the community based programs, whether they are Head Start, child care or state funded pre-school, don’t have the resources, expertise or authority to provide those specialized instruction and supports.
     DOE and HHS ensure the federal laws and guidance are clear that States and LEAs are required, or at minimum, strongly encouraged, to embed special education instructional supports and related services within the community based programs. This embedded support would also go a long way in building the capacity of the community based providers to support the diverse needs of the children in their care.

     Develop Models of Funding:
     DOE and HHS could also consider developing some funding models and guidance that States and communities could use that illustrate how Head Start, Child Care, and IDEA funding (in addition to State and local resources) can be used to build high quality early education programs, whether they are school or community based programs. There is often confusion at the local level on how IDEA funding can be leveraged to support inclusive classrooms.

     Increased Accountability and Information at Federal Level:
     The Ounce supports State Recommendation #3 that encourages States to set concrete goals for expanding inclusive high-quality early learning opportunities and tracking progress toward ensuring that more children are enrolled in those settings. This is another area where federal leadership could support this effort by requiring that these metrics be set and that the data be collected and shared at the national level. This data is critical to informing federal policy and investments that will promote and facilitate inclusion.

     Appendix C, Illinois Resources:
     Illinois, in large measure, due to the federal investment in the Race to the Top – Early Learning Challenge has embedded inclusion as an indicator of quality in its Tiered Quality Rating and Improvement System. At the highest level of quality, Illinois provides an Award of Excellence for Inclusion of Children with Special Needs to programs who show excellence in inclusion. The Award of Excellence is based on the principles in the joint DEC/NAEYC statement on inclusion. The Award and supporting resources, including Illinois’ Inclusion Guidelines, can be found at http://www.excelerateillinoisproviders.com/overview2/awards-of-excellence/inclusion-of-children-with-special-needs.

     In addition, in long recognition of importance of inclusive early childhood settings, Illinois’ State Board of Education has developed resources including an Inclusion brochure for families and professionals to better explain LRE and inclusion.
     Illinois also recently developed a new video that shows how Early Intervention services are provided in inclusive settings, and the important role that the teacher and caregiver plays in working with the Early Interventionist to support the child and family. The video can be found here: https://www.youtube.com/user/IllinoisEITraining.

     Thank you for the opportunity to provide comments on this bold joint policy statement on inclusion. The Ounce looks forward to partnering on these issues on the federal, state and local level. We welcome any opportunity to continue this dialogue with DOE and HHS to ensure that the issues that confront States and local entities can be understood and addressed as the federal agencies continue to elevate and prioritize the urgency of inclusion of young children, and indeed, all Americans, in all facets of society.

101. Thank you for this policy statement that summarizes the legal and scientific foundations of inclusion and the importance it gives to not only valuing inclusion but in actively working towards inclusive early childhood programs. As an educator, technical assistance provider, parent and long time advocate of inclusion I am so happy to see the support from both Department of Education and Department of Health and Human Services coming together to set the stage for inclusion in early childhood.

     This policy works to increase public understanding and provide the comprehensive recommendations and resources for states, LEA’s and early childhood programs to begin to change their systems. We can use this policy to move forward in increasing the inclusive options in all communities and increasing access that has not been available in many communities.
     Research demonstrates that inclusive early childhood experiences open the doors to lifelong learning, interactions, and achievements. Quality education and inclusive lives begin in early childhood and continues throughout a child’s life through school, employment, and the broader community.
     Like all children, children with disabilities must be exposed to a variety of rich experiences where they can learn in the context of play and everyday interactions and engage with their peers with and without disabilities. The best way to accomplish this is to assure we have high quality early childhood for each and every young child.

102. This is a well written policy statement. It covers the recent research to support inclusion and addresses all programs of Early Childhood Education. It is obvious to me that I lot of thoughtfulness, time and energy went into creating this document. I thank you for your work on it.

     I believe inclusion is critical for our youngest children and that we have a long way to go before we see inclusion that really works. This is a step in the right direction.

     I do have a few concerns about a policy statement.
     1. Currently funding structure promotes segregation. Currently with our funding structure we promote segregation by income and disability, Although all legislation for programs such as Early Head Start, Head Start, State funded preschool programs, Part C and Section 619 to name a few include language about inclusion about individuals with disabilities the reality is these funding sources are for a child with a designated risk factor and therefore encouraging segregation. Early Head Start and Head Start are for families that are economically advantaged – this means these children are not socializing with all children their age. If we want full inclusion we have to reduce and eliminate the separate funding streams and move toward universal early childhood programs.

     2. Funding. It will be very challenging if not close to impossible for states to implement these recommendations without substantial increases in financial support.

     3. EHS/HS a federal to local funding stream: The last issue that complicates having state recommendations is that EHS/HS is a federal to local funding stream. Because of this funding model it is challenging in implementing early childhood systems.

     Thank you for the opportunity to comment.

103. My academic placement was full inclusion in the mainstream from kindergarten to 12th grade. Profoundly deaf, I could not understand spoken language unless it was lipread slowly and clearly to me. Even then, I did not understand everything that was said. I was not given sign language interpreters. I had teachers who did not understand deafness. I was the only deaf person in my entire school. I sat through classrooms day in and out not understanding what was going on. I spent hours at home after school re-learning everything that I missed during the day. Back then, they showed movies without closed captions. They didn’t give me a script or anything to help me understand what the movie was about. Socially, I had few friends and was bullied by hearing peers all the time for being different. My opportunities in extracurricular activities were very limited. I was artistic, but yet was not offered to join clubs such as the Yearbook or anything that would help me develop my skills and career exploration.

     I have a master’s degree and a professional career, yes, but no thanks to being placed in a mainstreamed environment. I am in my career because it was all I knew as other members in my family were in similar careers as mine at the time I was applying for college. I would have probably done so much better and found a better-fitting career if I had been in a deaf institution with teachers who could sign with me and told me about many different careers that I could have explored. Being fully included, I missed so much information, knowledge, and opportunities. I am still suffering the effects as an adult…so please revise this law to allow the deaf and hard of hearing to have a continuum of choices instead of full inclusion. Please stop going backwards!

     • Thank you for sharing. We are in the same boats. It takes a long time to catch up what we had lacked in our growing up years in the non-ASL environment.

104. I teach Deaf preschoolers and I am opposed to this policy. A truly inclusive education for Deaf children means giving them the opportunity to learn alongside their Deaf peers in a language that is accessible for them. Inclusion is not a one size fits all model – applying that concept to our Deaf children would be a gross act of negligence, depriving them of language at an early age. Please reconsider this policy. Thank you.

105. I support this but the deaf and hard of hearing have a different language the dont develop a normal langauge like any other disable children. They use lot of visual and hands to communicate. You need to study more about deaf culture and understand the langauge that they learn as geowing up.

106. As much as we may embrace the principle of inclusion in education, we must also acknowledge that our free society enables self-selection of segregated settings, including educational ones. The parent of an infant/toddler with hearing loss ought to have a choice of mainstream pre-school, a school for the deaf/Deaf where American Sign Language is taught as the child’s primary language, and schools where intensive auditory-oral education prepares the deaf child for mainstream kindergarten.

     INFORMED CHOICE must be as important a value in our society as DIVERSITY and INCLUSION are. There are places in the world where a young child with the build of a gymnast would be taken from her parents and placed involuntarily on a path to Olympic glory. That should horrify us—but no more so than does the notion that American Sign Language is the “natural” language of those without hearing. Each morning, I join the hearing world by affixing cochlear implant processors to either side of my head. I interact with the wait person at the restaurant using spoken English, listen to my favorite music on the car radio, participate in conference calls where I work as a marketing consultant, and enjoy the company of family and friends in my leisure. At night, the implant processors go in the dry box and I rejoin the non-hearing world.

     I want people to respect the choices I have made, just as I respect the choices that others have made.

     Here in Delaware, our Birth-to-3 program has channeled families affected by childhood hearing loss directly into Delaware School for the Deaf for many years. Six years ago, a grassroots organization called Choices began working on changing this policy and practice. We have worked with members of the legislative and executive branches of state government. We have communicated our concerns to the Office of Special Education Programs and the Office of Civil Rights at the federal level. So far, nothing substantive has changed. Indeed, at this time, a state task force is working on changes that may create an even more monolithic, less inclusive structure for education of deaf and hard-of-hearing kids.

     And so, I applaud DOE and DHHS for recommending that state and local education authorities promote inclusive practices for pre-schoolers. But if this white paper has no enforcement mechanism, life in Delaware will continue in its dreary way.

107. Early childhood intervention and inclusion clearly benefits children WITH and WITHOUT disabilites. I have 50 years experience as an early childhood practitioner and have witnessed firsthand the difference in achievement outcomes of children with intervention vs. children without. There is an abundance of research validating that high quality early childhood programs with children with disabilities result in reaching their full potential, thereby contributing to society and becoming tax paying adults instead of consumers of public financial assistance.

     I totally support this bill. Susan G. Allen, MED, M.Ed, CCC-SLP, LSLS Cert. AVEd and retired after 50 years of dedication to improving the quality of life for children with disabilities and witnessing amazing results!

108. I agree with James Tucker what he say about the issues. Please don’t change it by policy because the children will confuse about the education and classroom. Don’t change and just leave alone them because they already develop own knowledge during school in classroom. Don’t mess up education with disabilities what they have.

109. If you understand my quote then you wont have any problem smile emoticon “Eyes are more important to be witnessed than listening our Deaf ears that doesn’t prove anything.. Our Deaf eyes are more of evidence to ourselves than hearing people who depends on their ears that can be more complicated in many ways.” That s the real reason for us to have American Sign Language that belongs to Deaf children and Deaf disabled children. Deaf will be always Deaf as is after all those lipreading, oral speaking, and listening are out of order for Deaf since it s no languages for us to have in our Deaf education. So remind you, we do not hear a spoken language with or without any of those deadly medical devices for us to understand. Time for you to leave us alone and our Deaf education with ASL that needs to get it back to our Deaf children and their Deaf standards to meet our BI BI languages which are American Sign Language and English written that is a real necessary for all of us, Deaf Diversity first in America. Thanks! All I can ask you to respect our Deaf language and civil rights that is a simple answer for you to accept us for who we are and what we are.

110. From parents, educators, and Deaf citizens, who know from first hand experience and observation, A Resounding NO to this deliberate rush without further sensitive language acquisition considerations, especially for d/Deaf and Hard of Hearing.

     No one size can fit for all.

     • From a basic need to understand why introducing the draft with the historical framework as a celebration in kind, as well as with what may be set forth with it, it seems to me that the length of time is then also with an understanding, especially. Re-sounding.

     • As a Deaf person, my school experiences in an oral school for the Deaf and in mainstreamed programs for the deaf may have prepared me for college. However, my personal growth was stunted as I was left out often socially with hearing peers. I acquired sign language as a teen and over time, I have become bilingual in ASL and English. This is a common experience for many Deaf people.

       On the professional side, I have worked as a parent infant program coordinator, preschool/elementary teacher and ASL Specialist for over 28 years. I have worked with Deaf and hard of hearing children who come from different educational settings. The biggest challenge has been with students who have “failed” in public school and placed in a school for the Deaf. Many of these students struggle to “catch up” in building a strong language foundation and real world knowledge in order to compete in the working world. It is NOT fair and so unnecessary.

       IT is crucial that you include the Deaf community and Deaf educators in this discussion as they are the experts. This draft may be ideal for many children with Disabilities. BUT it should not be considered for Deaf and hard of hearing children as written. Please pay attention to all of the replies regarding the laws related to Deaf Education which falls under Special Education. This proposal is not needed.

       Thank you,

       Wende Grass M.Ed.

       May 22, 2015

111. If you understand my quote then you wont have any problem smile emoticon “Eyes are more important to be witnessed than listening our Deaf ears that doesn’t prove anything.. Our Deaf eyes are more of evidence to ourselves than hearing people who depends on their ears that can be more complicated in many ways.” That s the real reason for us to have American Sign Language that belongs to Deaf children and Deaf disabled children. Deaf will be always Deaf as is after all those lipreading, oral speaking, and listening are out of order for Deaf since it s no language for us to have in our Deaf education. So remind you, we do not hear a spoken language with or without any of those deadly medical devices for us to understand. Time for you to leave us alone and our Deaf education with ASL that needs to get it back to our Deaf children and their Deaf standards to meet that is a real necessary for all of us, Deaf Diversity in America. Thanks! All I can ask you to respect our Deaf language and civil rights that is a simple answer for you to accept us for who we are and what we are.

112. Deaf and Hard of Hearing persons are very able-bodied people who happens not have the ability to hear, plain and simple. However educational systems for deaf children are a lot different from regular schools because they need trained teachers who are either Deaf teachers or teachers that are certified teachers with education in the Deaf Studies.

     Please do not compare deaf children and adults to other people with disabilities unless the deaf and hard of hearing have more than one ailment to fall in their category of the disabled people.

113. This policy statement is not needed. ADA and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion. We do not to create more confusion and problems in education.

114. I have been studying the acquisition of American Sign Language (ASL) for over 30 years. Most recently I have been studying the bilingual acquisition of ASL and English. Two things are very clear: (1) Deaf children can succeed with *both* ASL and English; and (2) such success requires an environment in which both languages are skillfully used and respected. In many cases, this means placement in a program providing rich ASL input as early as possible, so the child has access to a full natural language on which future learning can be based. This kind of input is not available in programs that are not specifically designed to provide it, so special consideration must be made for the individual needs of Deaf children.
     Bilingualism can be a benefit for all children – Deaf children using ASL and English; hearing children of Deaf parents who sign and speak; and hearing children using two spoken languages. What is crucial is rich access to both languages and visible respect for bilingualism.

115. Inclusion within quality programs is essential for all children. As a society, and especially as educators, we need to focus on the strengths of children in order to create meaningful experiences for all.

116. Reinforcing inclusive environments in early education does a number of things. It Encourages the teachers, directors, and staff members to get professionally trained in many domains to detect, manage, and include children of all needs. The Provider then transfers over the evidence based practices and knowledge to the families so they in turn, can better care for and meet the needs of their child/ren. Money from participants goes back into the CCRRs programs funded by the state to continue to support the quality care in education, and service these very same families in need. Child care would have to develop their infrastructure to accommodate the needs of all children. Inclusion will reinforce curriculum to meet the needs of all learners. Most of all, children will have the equal quality educational environment that their peers who are in regular education get. Children who grow up with peers that are diverse grow to naturally be inclusive, and more productive citizens. Children who are disabled most benefit.

117. I have read many of the comments regarding this draft and the positive or possibly negative affects it may have on disabled preschoolers, in particular Deaf/Hard of Hearing children. Having worked for 25 years with this population in the mainstream setting I do support the need for a continuum of services and feel it is important that this proposed draft be sure to include wording that will allow for choices and options. Meeting the needs of D/HH children is a very murky venture with no clear cut way to meet each child’s needs. Ultimately it is the parents job to decide what will be best suited for their child and family but first they must have the choices. There are so many different vairables when it comes to evaluating a D/HH child’s needs. I have seen Deaf students that would succeed best in an ASL program while students with Cochlear Implants that are considered Deaf, thrive nicely in the mainstream. If parents are made to feel that it is an either or option of an ASL program or a mainstream setting with limited supports then we are failing them. Inclusion is best only when there is adequate supports for both child and family that produce positive growth and outcomes. Let’s make sure that all supports and options are available to all D/HH students.

118. This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. Also, the word “inclusion” IS NOT ANYWHERE IN THE LAW- This draft guidance misinterprets the law and creates confusion.

119. I am a speech-language pathologist working on Long Island in a special education school for 23 years. I have worked in a variety of settings which include: self-contained classrooms and inclusion classrooms. I feel that the inclusion model is not appropriate for all children. For many years, I have worked with special needs children and feel that the individual needs of the children must be considered for proper placement based on their needs. The ultimate goal is for children who are placed in self-contained classrooms learn the necessary skills to eventually be part in an inclusion or mainstream environment. The ultimate goal is an inclusion class; however each child has different needs and functioning levels and may not be able to handle the quick pace environment of an inclusion setting. I feel that there needs to be a continuum of services based on IDEA. I am not in favor of the policy as proposed for inclusion. The decision should ultimately made by parents and professionals to look at each individual child and their needs.

120. I am hard of hearing and was mainstreamed (in the 1950s’) without any educational support. It was far from ideal, but given the amount of my residual hearing and ability to communicate aurally and orally, placement at the local school for the Deaf would have been an entirely inappropriate fit for me. I succeeded in school despite my hearing loss.

     My son is classified as hard of hearing due to unilateral deafness. He had far more educational supports (in the 1990’s) than I could have ever dreamed of. He had a hearing aid, he and his teacher wore a wireless FM system, he had an Educational Consultant who specialized in kids with hearing loss who trained his teachers every year and visited the classroom and my son regularly to check up and tweak the program supports. My son did very well in school and thrived with this support. Despite his profound unilateral hearing loss, he was not in any way an appropriate candidate for the local Deaf School. (Though I did get “heat” from some people in the Deaf community for not enrolling him.)

     To often when discussing educational inclusion programs for children with hearing loss the terms “Hard of Hearing” and “Deaf” become conflated. Too many people believe the educational, social and emotional needs of a child who is Hard of Hearing are best met by a pure ASL Deaf program.
     This simply is not true.

     An analogy to this thinking would be to place all school aged children wearing glasses in a school for the blind. Remove their glasses, and provide them with black lenses and a white cane and train them to function without using their residual sight. It makes no sense. Well, it makes no sense for children with hearing loss either.

     I do not mean in any way to disparage the ASL Deaf Educational programs. They are essential for the healthy social, emotional and educational development of profoundly Deaf children. ASL is a beautiful, effective and powerful language. The Deaf community is an active, vital and important cultural asset for the Deaf child and everyone else in America. (Ask me where the football huddle started!)

     But there is a world of difference between the needs of a profoundly Deaf child who is painfully isolated in a mainstream program and needs the linguistic, social and emotional support of an ASL peer environment, and a hard of hearing child who is able to use residual hearing with hearing aids, FM loop system and educational supports to thrive socially and educationally in a mainstream classroom.

     Every child with a disability has a right to utilize and develop whatever innate ability and strength that they already have. For most hard of hearing children this ability includes residual hearing and intelligible speech. Technology and specialized support can enhance these skills. But, both of these abilities are downplayed, devalued (and sometimes actively discouraged) in a Deaf cultural setting. It is not healthy for a hard of hearing child to have to hide or stifle their ability.

     The decision of educational placement and services MUST be tailored to the individualized needs of each and every child with hearing loss depending on the degree and type of hearing loss, regardless of political or cultural bias.

     Thank you for taking my comment.

121. Although I support that the goal of Preschool Special Education is to integrate children as early as possible to the mainstream community, such is a uniquely individualized decision. It is not a ” one size fits all” solution.
     I do not support the proposal written by the Department of Education which neglects to understand the importance of the IDEA law. Each child ‘s readiness for inclusion is individual. All children with disabilities must be served based on their individual needs. Placing children in an inclusionary setting before they are ready will have a detrimental effect on their continued success. It is the collaborative responsibility of the parents and professionals working with each specific child to determine which placement is in the child ‘s best interest. The continuum of services specified by the IDEA act must not be ignored!

122. To The U.S. Department of Education and Department of Health and Human Services
     On behalf of the Deaf and Hard of Hearing Community,
     Stop forcing every deaf and hard of hearing students into the full inclusion.
     Do not violate human rights of every deaf and hard of hearing students. They have rights to be whole persons by having full access to visual language, American Sign Language and written English and social and emotional skill developmens. Being wholly human and having happiness come first.
     Again, I say that forced inclusion is not the solution to every child with disabilities. Otherwise, many of them might go back to Dark Ages which would be much burden on the taxpayers in the future. In other words, it would be a bad invesement in the future of deaf and hard of hearing persons.
     Thank you,
     Peggy Hlibok, a community advocate and a retired educator
     Albert Hlibok, a former secretary of the National Association of the Deaf and a leader at all levels(national, state and local)

123. I have studied the acquisition of American Sign Language (ASL) for over 30 years. Most recently I am studying children who are growing up bilingual in ASL and spoken English. Two things cannot be disputed here: (1) Deaf children can succeed with *both* ASL and English, and (2) such success requires an environment in which both languages are used skillfully and respected. For Deaf children, an accessible language-rich environment starting as early as possible is least restrictive and most effective. In many cases, this means *inclusion* in a special program designed to provide access to rich ASL input for a foundation on which all subsequent learning is based. In the absence of a signing community, many Deaf children will be *excluded* from language and learning.
     Please keep in mind that bilingualism should be valued for hearing children too! Bilingualism is a benefit, as long as children have sufficient input in both languages. Children are sensitive to the language attitudes of those around them, so they need to see respect and encouragement to be able to take advantage of their early language-learning abilities. These considerations favor individualized attention that means different placements for children with different needs.

124. While I am sure the intentions and beliefs for creating this draft are good but IDEA has been interpreted inappropriately and the agencies writing this draft really overstepped their bounds on this. IDEA already mandates that there should be a continuum of options available for infant/toddlers and children for individual plans that would meet their unique needs while satisfying the mandate of natural environment (Part C) and LRE (Part B). Like many people mentioned earlier, the suggestion that all children can be appropriately served in one type of setting is completely false. The point of having a team for the IFSP/IEP is to be able to collectively examine together what the individual child needs, so creating an overarching national pressure for full inclusion for all children takes away the ability for the team to make decisions that are responsive to the child. Instead, there will be pressure to comply to a certain number by the system forcing the team to take their attention away from meeting the child’s needs to worrying about meeting the system’s arbitrary magic number. Sometimes what is currently labeled as “Most Restrictive Environment” by the system is actually the most effective (cost-wise and result-based) in assisting the child in developing the necessary skills to function in school and society successfully. I am a mother of two deaf children and both attended different types of placements according to their needs. The proposal for full inclusion is well-intentioned but misguided as it would also promote permanent eradication of these vital and already effective schools/programs that are outside of what they view or define as “full inclusion.” As a deaf person myself, I can testify that sole mainstreaming (being the only deaf individual in the school) was THE most restrictive environment for me even though it met the court’s definition of LRE (it was a local school, I was with non-disabled peers, and it provided the required services for me). Even though I could speak “well enough” and “hear well enough” to should be able to do well, by their assumptions, It was actually the most isolating and emotionally-socially harmful environment for me, I was on the verge of dropping out of school completely. It was not until I was able to attend a deaf school that I thrived, having a full accessible environment where I could interact with my teachers and peers directly that it was truly what was the least restrictive environment for me. The result is that I eventually went on to earn my doctorate and become a full participating citizen, and I strongly believe it was because of being able to go to this school. Deafness is often overlooked in the category of disabilities. Its challenge is not a physical or cognitive barrier but rather a communicative barrier so, to demand that ALL deaf/hard of hearing children be forced into a more restrictive communicative environment simply because they fall under an umbrella of “disabled” category goes against the intent of IDEA. I am a staunch advocate for early intervention and early education as they are undoubtedly very important on setting the foundation that supports the kids’ success down the line. If it so happens to mean that they are able to access what they need in a local school, then that is fine. However, the ideology and assumption that LRE ultimately means full inclusion is based on a faulty fallacy and the real-world implication would lead to termination of the specialized instructions programs/schools that students with disabilities may need and this would cause irreversible harm to some of the kids in the process. There are several research that have examined the outcome of inclusion on deaf and hard of hearing children for the past thirty years and the results are not so great. So, we need to be careful about generalizations across subgroups within the disabled population, as each has their own data. So, before pushing for a blanket statement determining WHERE the child goes to get their education is going about it in the wrong way. Rather we should push for the true intent of this proposal which is ensuring that kids with disabilities are ABLE to obtain quality early education that they individually need. That is the ultimate goal.

125. I’ve read this all above.. I wanted to say something but you say it all . Best bet is don’t take this away from us. We have some purpose this for the future. God Bless America.

126. I am concerned with the policy statement on Inclusion of Children with Disability in Early Intervention and Early Childhood Programs. Inclusion will not be a benefit for deaf and hard of hearing because of greater difficulties with communication with peers in general education settings. Deaf children will always be isolated in any intervention and early childhood programs because they always are left out of groups, activities, classes, and sit alone in the cafeteria. It’s unavoidable, because teachers, interpreters, and hearing students can’t communicate the way they want deaf students to, and they still don’t understand them.
     I support IDEA that requires the child to be appropriately evaluated by evaluators, IEP team. They develop appropriate goals and needs for deaf and hard of hearing. High quality programs that include least restrictive environment save MONEY and improve outcomes. Deaf schools give deaf and hard of hearing children full access to full language and communication and equal educational opportunity. They have raised expectations for what children can achieve education and language and meet the learning and development needs of all children. I am proud of my two deaf and hard of hearing children who graduated from college. My hard of hearing daughter will be a third-year law student in the fall.

127. Deaf and hard of hearing children are NOT given the least restrictive environment nor the optimum education in an inclusion environment. Multitudes of deaf children are being deprived of language for the most important years of their lives in relation to language development due to the emphasis on inclusion or mainstreaming. When these children are given access to a special school for the deaf at the earliest possible moment and that special school is FULLY supported by it’s department of education, these children and their families thrive. The children that are deprived of this access struggle dramatically to make the gains in language and cognitive development. The families must spend all of their time and energy finding access to the tools that a special school would provide. These families must quit jobs and live in poverty just to find time and opportunities to provide their child the access to language that is provided by special schools for the deaf and hard of hearing. Many families are unable yo make this sacrifice and what has occured is generations of deaf and hard of hearing children who have been deprived language and cognitive development that is available. The emphasis on inclusion has had a dramatic and negative impact on the education of deaf children. Special schools for the deaf have been closed throughout our nation and deaf and hard of hearing children have been put into an environment (inclusion/mainstreaming) that offers the MOST restrictive access to language and cognitive development. As the mother of a deaf child who moved across the country to give my daughter access to a special school for the deaf that was supported by their department of education, I entreat the Department of Education to do more research related to this group of children. As the Guardian of a child who was a victim of inclusion/mainstream whose family could not sacrifice any more than they already were and comparing this child’s experience to the experience of my own child, I can tell you that Special schools for the deaf and the full support of the department of Education for these schools is the avenue for deaf and hard of hearing children to have access to the best possible education. Please contact the experts in educating deaf and hard of hearing children through out country and read the research that shows the the current inclusion/mainstreaming environment is detrimental to the group.

128. the draft policy completely ignored the question of the right of the individual to choose the best program, be it mainstreaming or a specialized school such as for the deaf and blind. I have been through both , I lost 10 years of my life in a mainstreaming environment which did not prepare me for the world. It was not until I attended MSSD (Model Secondary School for the Deaf) , where I was given the freedom to proceed with my life rather than be dictated by a board of IEP experts that did not have any ability to improve my situation. I ask that the Department of Health and Human Services to rescind this document and desist in further discussion at the disadvantage of the Deaf and Blind community . Please talk with those who know and stop patronizing us!

     Sincerely ,

     Philip L Bergstresser

129. Deaf and Hard of Hearing must place with all deaf and hard of hearing peers together in one category “deaf and hh classroom” not with the mental ilness or blind peers. They must communicate in American Sign Language and Cued Speech. Do not place deaf and hard of hearing into severe disabled peers.

130. I am a speech language pathologist working in a special education setting in Long Island, New York. I have worked in a variety of settings, inclusion and self-contained. I have worked with special needs children for many years and feel that the inclusion model is not appropriate for all children. Although it has benefits the individual needs of the child must be considered for proper placement. Some children who are placed in self-contained learn the necessary skills to eventually participate in inclusion or mainstream environments. There needs to be a continuum of services based on IDEA. Each child had their own path, obviously with inclusion being the ultimate goal. I am not in favor of the policy as proposed for full inclusion. The decision should be made by professionals and parents who take into consideration the specific needs of each individual child.

131. As the president of the Florida Coalition for Spoken Language Choices and the parent of a deaf child, I fully support high quality inclusion for the majority of deaf and hard of hearing children.
     90% of deaf children are born to hearing families and those families are overwhelmingly choosing access to sound through hearing aids and cochlear implants along with listening and spoken language. When appropriate, high quality interventions such as specialized LSL/OPTIONS schools are given in a timely manner, these children are mainstreaming in preschool and kindergarten without the use of ASL.
     My own son entered a mainstream classroom in first grade, without need for an interpreter. He listens, speaks, reads, and writes on grade level. He interacts with hearing peers and teachers throughout the day using listening and speaking. Meaningful inclusion environments have been crucial to his linguistic, social/emotional, and educational development since infancy.
     There will always be deaf individuals who will benefit from visual languages like ASL or cued speech. Communities of visual communicators are important in those cases. However, even deaf individuals who communicate visually should have maximum access to public venues, situations, and education. They have a right to meaningful inclusion in all of society including public education.

     • With all due respect, I feel the need to point out that your son may not have been able to attend a mainstream classroom if he had not had the specialized intervention he had received in a non-inclusive setting when he was younger. As the current policy is written, you/your son would have been at risk of not having the opportunity for specialized intervention because he would have had to be included in a general education early childhood/early intervention program.

132. I am a High School principal at a Deaf school, and even though 60% of our HS students enroll in either the Middle School or early HS ages, we consistently have HIGH academic growth year after year. Keep in mind, these students come to our Deaf school late, and are already at a disadvantage compared to those who grew up at our school. HOWEVER, once they are in an actual educational environment, their scores soar like never before.

     I know the forces behind this want you to keep remembering that the “average Deaf graduate reads at (x) grade level” (whatever that is- 3rd or 6th— still far below), but what they DON’T want you to remember is…

     …over 80% of Deaf school age children in the United States are *NOT* educated at Deaf schools or bilingual (ASL-English environments)!!!

     Whereas those in the 20% or less consistently have higher academic rates. For instance, here in California, with our (now defunct) HS Exit Exam, both Deaf schools’ students scored the HIGHEST in the state.

     Basically, it is an ongoing lie that non-Deaf people know what’s best for Deaf children, that Deaf = disabled, and that it’s Deaf children’s fault that they graduate at such a low reading level.

     The U.S. public educational system should be following the Deaf school model, not the other way around! Yes, if only hearing children in U.S. public schools were in similar environments as thriving Deaf schools, ALL academic scores will be in the stratosphere.

     REFORM the U.S. public educational system into our models!!!!!

     • I disagree, D. Eberwein. The U.S. public educational system should NOT follow a Deaf school model. Quite alarming to even suggest that. Rather there should be options on the kind of schools available with the various support system in place. Success can be seen in every aspect on the modes of communication used in educational settings such as SEE, Cued Speech, ASL, auditory-verbal, and so on for students with hearing aids, cochlear implants or none at all. There is no one size shoe fits all here. Yet, inclusion can work for some, others it does not. It would require an individualized approach rather than a blanket approach. Inclusion has worked for me. It has worked with numerous others I know of. While for others it did not. But that’s the past. The past cannot measure up to today’s vastly improved services, communication and educational technology, hearing technology, educational knowledge and understanding.

       The key item here is early intervention. It helps set the language foundation whether it is the English language or ASL.

       Not using ASL does not necessarily preclude the learning of the English language and its foundation. Use of Cued Speech, SEE or even auditory-verbal has shown successes on helping establish strong English foundation and in turn help provide a successful educational results in school. Such example could be the Northwest School for Deaf and Hard of Hearing:

       *Nearly all of NWSDHH’s students (98%) graduate from high school with reading and math skills above, at or near grade level. *Nationwide, only 40% of deaf and hard-of-hearing students reach this level of academic achievement.
       *100% of our students graduate from high school, compared to only 76% of deaf and hard-of-hearing students nationally.
       *Close to 9 in every 10 NWSDHH alumni go on to study at a post secondary level, with 67% completing their degree. Nationally, less than 7 in 10 deaf or hard-of-hearing students enroll in a post-secondary program, and of those less than 30% graduate.

       http://www.northwestschool.com/about-us/graduates-succeed/

       Sometimes inclusion works, sometimes not. Some would do well in specific, well supported environment like deaf/hh oriented schools based on a variety of educational and communication philosophies. Many have done well in regular school settings.

       Even if you have some deaf students who have been coming to your school since the early grades, D.E., the school should still show more students with higher achievement results in California STAR reports going back 15 years for Fremont. But that’s not the case. Of course, you could throw out the multiple-disabilities as one of the reason for the low scores. An oft repeated excuse. Some of it valid but for the whole school population? What about deaf of deaf? there should be enough of them to show the higher scoring results but not so.

       So, that’s one of the reason why I’d be reticent on supporting any idea of using deaf schools (ASL) as a model approach for the U.S. public educational system. Some approaches have merits but as a total model approach? No.

       http://star.cde.ca.gov/star2013/ViewReport.aspx?ps=true&lstTestYear=2013&lstTestType=C&lstCounty=01&lstDistrict=31617-000&lstSchool=0131763&lstGroup=1&lstSubGroup=1

133. As the principal of a “segregation” school let me express my dismay with this proposed policy. First, the use of the word segregation is inflammatory and misused. We do not segregate, we promote students with disability to be the very best they can be. Our goal is to teach the skills these students need and then get them back to the public school. Re-integration is always our goal. Second, to refer to public school programs as “high quality” implies that programs like mine are low-quality. My staff need to hold 2 or more certifications from the state whereas their public school counter parts need only 1. My staff attends more hours of meetings a month then public school teachers do in a year. My staff do not get lunch, they eat with their students. Their preps are often pulled for coverage needs because we cannot hire substitutes to do what we do.
     This policy is unneeded. The LRE component of IDEA is already clearly delineated. and while inclusion has been shown to work for some special education communities, this policy would effect all the other communities where inclusion makes zero sense. My students were asked or told they could no longer attended the public school. They were labelled the “bad” kid and targeted by peers and staff. When I discussed this policy with my parents at a monthly meeting I had several openly cry, in fear their student would be forced to return to public schools. I am not saying inclusion does not work. I’m not saying schools like mine are the answer to every educational need. What I am saying is that a policy that defines the LRE as the mainstreamed classroom, is foolish and overly general. There is no possible way that every student with every disabling condition can be served equally. Nor should it be a goal. Leave IDEA alone, it already recognizes the continuum of educational placements available.

134. 1) Deaf and hard of hearing children suffer from language deprivation when they are placed with hearing children with lack of full resources to ensure language access (qualified interpreters, teachers knowledgeable about visual aspects of bilingual learners, accessible technology like captions, flashing fire alarms)- and it would be both an impossible task and an undue burden for every early intervention environment and early childhood education classroom to provide the above simply due to deaf children being both unique in their language abilities and being a low-incidence disability group.
     2) This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. Also, the word “inclusion” IS NOT ANYWHERE IN THE LAW- This draft guidance misinterprets the law and creates confusion.
     3) Deaf and blind children have unique resources in state schools and large mainstream programs that are absolutely necessary for a majority if not all of the same children due to the access to qualified professionals who are trained and experienced in working with deaf and blind children and their families. On average, a public school teacher sees a deaf child once every 7 years- so how can teachers prepare for this occurrence, much less an early childhood program which are already provided by numerous deaf-specific programs. This policy paper will destroy those hard-working schools and programs which have worked for years to build up knowledge and expertise to ensure our deaf and blind children have the best language foundation. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers.

135. As the president of Michigan Deaf Association, our statement on this draft policy are:

     1) Deaf and hard of hearing children suffer from language deprivation when they are placed with hearing children with lack of full resources to ensure language access (qualified interpreters, teachers knowledgeable about visual aspects of bilingual learners, accessible technology like captions, flashing fire alarms)- and it would be both an impossible task and an undue burden for every early intervention environment and early childhood education classroom to provide the above simply due to deaf children being both unique in their language abilities and being a low-incidence disability group.

     2) This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. Also, the word “inclusion” IS NOT ANYWHERE IN THE LAW- This draft guidance misinterprets the law and creates confusion.

     3) Deaf and blind children have unique resources in state schools and large mainstream programs that are absolutely necessary for a majority if not all of the same children due to the access to qualified professionals who are trained and experienced in working with deaf and blind children and their families. On average, a public school teacher sees a deaf child once every 7 years- so how can teachers prepare for this occurrence, much less an early childhood program which are already provided by numerous deaf-specific programs. This policy paper will destroy those hard-working schools and programs which have worked for years to build up knowledge and expertise to ensure our deaf and blind children have the best language foundation. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers.

     • As a hard of hearing child of deaf parents, I attended a deaf school from the age of 3 until 9 then I was sent to public school (because I could hear and speak well) where I was “lost” to the hearing world. Although, I survived and graduated from public school, no matter what accommodations were provided to me, I did not have access to the social environment that a deaf child would have in a deaf school setting. No role models, no peers like me, no access to social enjoyment in a school setting, no access to full communication environment. I was never encouraged to succeed and aim for higher education while attending public school. I was lonely and alone. Although I could function ”just fine”, my hearing was not as good as my ability to speak. I did not thrive during my 10 years in public schools…for 10 years, I struggled silently. Only when I enrolled at Gallaudet University (through encouragements by a few deaf peers who happen to tell me about the university), my world opened up and I thrived! Access to communication was available to me 24/7 and there were so many role models that I was able to look up to. I was motivated to succeed. It was endless.

       Do not be fooled by the idea of deaf children to be able to function in a place that is inclusive. Deaf/hard of hearing children should not be lumped together and placed with other children with other disabilities. I could definitely see that children with other disabilities (other than deafness), inclusion could and would work for them to thrive and grow. However, for deaf and hard of hearing children to be placed in this environment would be counterproductive and a grave mistake. Inclusion is definitely not a one size for all! Placing a sign language (ASL) interpreter in a classroom for deaf/hard of hearing children is not the answer either. Learning does not end in the classroom. Social development is just as important as education in a learning environment as well as the ability to communicate with anyone (counselors, teachers, athletic program teachers, office staff, etc.)!
       The policy makers need to step back and separate the deaf/hard of hearing population from the rest of disabled children. This policy is not necessary…we have the ADA and Section 504 that states requirement for early childhood programs to be accessible to children with disabilities. Also, schools and programs for deaf and hard of hearing children must include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and families. Continue supporting deaf schools that offer wide range of support for deaf and hard of hearing children and parents. Believe us, we know!

       Thank you.

136. Question :

     Do you honestly believe that all children with disabilities benefit inclusive environment prior kindergarten? If so, then I ask you, is your disabled child have a full access to language through auditory channel? FULL ACCESS, without any hearing technology. Then it is inclusive for them.

     I am speaking for Deaf and Hard of Hearing toddlers with assistive hearing devices (cochlear implant, hearing aids, BAHA systems, etc.), and do you truly think they can be fully inclusive in an environment where spoken language is used at all of the times? If you say yes, you truly miss the point.

     If you truly think Deaf and Hard of Hearing toddlers can use sign language interpreters, CART systems, or any kind of transliteration to help them to access information in an inclusive environment, the answer is no.

     That is ONLY if they acquire full language first before using auxiliary support systems. They need to be in a language-rich environment with their peers to acquire a full rich language (ASL and English) that is accessible to them.

     Putting a Deaf or Hard of Hearing toddler in an inclusive environment where spoken language is used, does not mean they are accessing to full language. This is to isolate them in an “inclusive” environment.

     Please do not clump Deaf and Hard of Hearing children under an umbrella of all other disabilities.

     It is a dangerous precedent for you to develop a policy without consulting with experts working with Deaf and Hard of Hearing toddlers and children.

     I oppose this policy statement as written right now, and it is strongly suggested that we amend a statement which emphasizes language needs of the Deaf and Hard of Hearing toddler and young children.

     Thank you.

137. As a Deaf citizen and a mother to 3 Deaf children I object to this draft. The Deaf community is a culture and have a language of our own which is ASL. We can function and learn just fine we must keep this in mind. It’s important to meet each deaf child’s needs accordingly. This draft may work for other disabilities; however, it will not help our fellow Deaf children. Please revise this Draft and listen to what the Deaf community and James tucker has stated. Thank you.

138. As a long time special educator, I applaud the effort to expand supports for children with disabilities in inclusive early childhood settings. Indeed, we need more high quality inclusive early childhood programs.

     However, as a number of respondents have so eloquently noted, sometime intensive specialized supports are required for children with blindness and sensory disabilities and children on the autism spectrum to prepare them for those inclusive settings.

     We need a continuum of options that are individualized for young children with severe sensory disabilities. Preparation for braille and orientation and mobility begins soon after birth, and children with low vision and blindness have other unique needs that must be addressed by special educators who are teachers of students with visual impairments. The ultimate goal is full participation in inclusive settings; however, specialized support must be available for all children with sensory disabilities.

139. I too support this policy and hope it becomes law. It is a right that every child has. I have a nephew recently diagnosed with ASD. He is a very social, high functioning little fellow. I would not want to see him in a segregated setting. Every child has the right to grow up, feeling confident and having a sense of belonging.

140. Fundamentally, in my experience 2 things are high risk here. The lack of special needs training the average teacher gets (1 semester) and the lack of staffing, and unfunded federal mandates. These can result in a very chaotic classroom. Inclusion is very important, but for some kids it can add immeasurably to their daily stress (as it did with mine). When there are too many mandates, that cover the requirements of the teacher (over sized class, common core, state testing, state mandated teacher effectiveness reviews) the teacher may have a tough time, not being terrible stressed when trying to teach. I have seen this as a volunteer in my community schools. Kids, like my son who has Asperger’s, can be caught in the crossfire of staff stress, and other kids who like to bully, or who also feel stressed by the requirements they are under. Special needs students, need staff who will take their needs seriously and meet them. All too often, what I have gotten is “lip service” compliance for the IDEA act and other Federal requirements. Substance is often lacking. There are many excuses given, lack of funding, the lack of staff training, lack of supervision of students, and lack of academic supports. As a parent, I eventually burned out on trying to get the services my son needed, exhausted I settled for an online school until I can move him to another state, where I hope that things are better for students with his disability. All in all, there is no oversight, and little enforcement (without legal threat) of the rules and requirements laid out in these documents. Because each region in the US has such varying beliefs, values, and attitudes towards those who are “other” abled, I find it challenging if not impossible, to conceive of a “one size fits all” solution for classroom integration. I am not one to shirk challenge, but I have seen my gifted Aspergian descend into the depths of severe depression while in a school environment that despite it’s inclusion, made him feel terrible about himself. Inclusion is only as helpful as the ability and attitudes of the people one is being included with, otherwise it seems that it can fuel the fire of self hatred for being different.

141. As a president of Oregon Association of the Deaf (OAD1921.org) –

     We have 1,047 students with primary or secondary diagnosis with Deaf in our state’s school system.

     There are 186,117 Oregonians with hearing loss.

     We only have under 350 American Sign Language interpreter to respond to the statewide need from womb to tomb that includes health care, employment, education, independent living, and so forth.

     Not enough resource in this state to satisfy the proposal written by US Department of Education and this is true for many of other states.

     American Sign Language is primary language in bicultural and bilingual education approach in teaching the Deaf, DeafBlind and Hard of Hearing children in K-12. In our nation, we saw significant and inadequate resource available to address the proposed to inclusion the Deaf, DeafBlind and Hard of Hearing children in education. This will do more damage than providing benefit to the Deaf, DeafBlind and Hard of Hearing children.

     The Deaf, DeafBlind and Hard of Hearing children shall remain in “State school for the Deaf” and “self-contained classroom” in mainstream schools taught by qualified Teacher of Deaf or Hard of Hearing (TODHH).

142. It’s welcome news that the Departments of Education and Health and Human Services are jointly preparing a policy statement on Inclusion with Children with Disabilities. There is much to like in what is being proposed.

     The opportunity to provide comment on the draft is very much appreciated. For ease, my four comments are offered in list from below.

     *I missed seeing commitments from the departments regarding their intentions for facilitating implementation of the recommendations. Identifying these intentions would increase the statement’s impact as well as transparency.

     *State Recommendation #1. The quantity of existing state- and local-level interagency task forces and plans is legion. Too often, though, these entities lack authority, act independently of on another, and/or lack the organizational capacity, including resources, staff, and collective know-how, to effect meaningful change. This recommendation would be further strengthened if these well-known concerns were acknowledged and addressed as part of the recommendation.

     *State Recommendation #2. This recommendation seems repetitive of the charge given to State Early Childhood Advisory Councils as part of Head Start Reauthorization and also of expectations associated with the Race to the Top – Early Learning Challenge. If intentional, signaling this redundancy would highlight that the statement is not only cross-departmental but also one that is cross-initiative and cross-sector.

     *State Recommendation #6. As noted by the recently released IOM report, current professional development approaches are insufficient for addressing the competency of the ECE workforce at a level or scale that impacts its collective competency to support children’s learning and development in typical as well as inclusive settings. This means achieving the aspirations for inclusion necessitates going beyond the status quo. In conjunction with the IOM recommendations, this recommendation could be strengthened if it went beyond encouraging professional development experiences as presently delivered to highlighting the importance of lifting the overall level of competent practice in early childhood education.

     Thank you again for the opportunity to provide input. Your efforts are appreciated.

143. Focus on child’s needs FIRST is the key to success; therefore IEP is a sufficient policy. While I can understand other disability group’s concerns about excluding them from the society, however this policy is trying to drag other group, like deaf into “one size fit it all”; at whose expense?
     Researchers have shown that earliest language acquisition will benefit children thought-out their lives; therefore language rich environment, sign language and bilingualism approach is the answer for deaf children. The new policy will create an impossible undue burden for local schools to provide this; especially that it will be considered a language deprivation if it’s not met. It can be considered a human right violation. What about social interaction? Who will be responsible for this? There are deaf people who have uncomfortable childhood experience due to the pain of isolation and loneliness they experienced due to lack, limited or/and poor language access; sign language at their neighborhood schools. It is no secret that people who are socially isolated tend to be at greater risk of health issues. Who’s responsible for these negative outcomes? Schools that provide language rich environment due to large group of deaf students will contribute to a positive self-concept.
     Schools that provide bilingualism environment have higher academic achievement in later years than do students who don’t.
     The draft policy is poorly written as it will open a floodgate to definition of “high quality” and create more complications of the meanings of this new policy. It simply adds more layers and confusions therefore no need to have this draft policy in place.

144. I have seen the results of mainstreaming: isolation and inadequate academic skills. I need only point to the following:
     “Although experts suggest that deaf and hard of hearing children who receive appropriate educational and other services can successfully transition to adulthood, research indicates that many do not receive the necessary support early on or during their school years to keep up with their hearing peers. For example, according to one study, the median reading comprehension score of deaf or hard of hearing students at age 18 was below the median of fourth grade hearing students (May 2011 Report of Deaf and Hard of Hearing Children: Federal Support for Developing Language and Literacy 2011, 1).

     I beseech you to understand that mainstreaming young deaf children in a hearing environment, without peers and teachers who know ASL (a complete visual language) and can use it directly, is a travesty and continues to decrease the possibility that the child will acquire language in the natural way children acquire languages around the world.

     Would you send your pre-school child to a school where he/she did not know the language, couldn’t hear it and had to converse through an interpreter without direct spontaneous conversation with peers and teachers? If your answer is ‘no’, then realize the consequences of your actions: deaf children are isolated in a hearing environment. They don’t pick up language unless they see it. It is impossible to follow a spoken conversation that involves more than one person as they won’t even know that someone has spoken, yet alone the content of what they said. Language denied leads to language delayed . . . for a lifetime of illiteracy, that recent reports confirm.

     Inclusion is NOT mandated by the IDEA. Parents and competent evaluators need to be involved in the IEP process so that appropriate placement, with a wide range of options including special schools for deaf children, should be determined by those qualified to do so and those who know the child best, not by those who believe that mainstreaming is a one size fits all event.

     As the author of a recent book about sibling relationships, “Deaf and Hearing Siblings in Conversation,” I want to draw your attention to the importance of siblings who are one another’s first social agents, having a shared language to use with one another. Deaf adults and their hearing siblings we interviewed, looked back on their childhood experiences and spoke of the isolation they had in their families, where they were present, but not present because access to ongoing, spontaneous conversations was absent in their hearing families. These isolation experiences continued into their adult lives and are parallel to the preschool mainstream that you are mandating in your proposal. It would be tragic to continue the isolation that has obstructed hearing and deaf sibling relationships by perpetuating that isolation in deaf pre-schoolers’ daily lives.

     I speak not only as a professional educator and ASL interpreter but as someone with real life experience. I am a hearing person with hearing parents, a hearing sister and a deaf brother and several other deaf relatives. My deaf brother grew up at a time when sign was not acceptable, so our family did not use sign language and my brother was raised in a loving home that only used speech and lipreading to communicate with one another. He, like the deaf adult siblings interviewed for the book, looks back bitterly at the times he was told “Never mind. It’s not important” or missed what the family was laughing about and only got the summary of the incident but never the meat, which is what stimulates and nurtures human relationships. This isolation and denial of their needs, is what pre-schoolers, who are at critical stages for acquiring language, will have to live with if ‘mainstreaming’ is the mandated first choice. That choice is the most restricted environment and I urge you to revise your proposal to reflect the language acquisition needs of deaf children who need to depend on their vision to acquire language and develop family, school and community relationships through spontaneous conversations that are accessible to them.

145. Hello everyone, I’m from in Canada Ontario. I knew Ontario have 4 school different a place for a deaf school but 3 different school are really far away and lots lots deaf people are really need stay open deaf school in Milton and Milton deaf school and any deaf are very a special whoever any kids r really need a deaf school and great memory school from history too.. My old school Milton deaf school please still leave on for them all deaf because I see government are still trying to close down my old large deaf ECDrury Deaf School in Milton. We all need keep Milton deaf school to stay cuz it close them’s parents better than three school r too far and kids can’t afford to stay over night all the weeks they need a parents

146. Hello!! I’m a former long time Deaf Advocate for Indep living center for Deaf! I strongly believe that Deaf and HH need to stay among with other Deaf peers not with hearing!! Very important to keep Deaf cultural ALIVE !! We have so many great Deaf Role models to help other Deaf!! Please see this info —> in Article 24 Section 3(c.) of the Convention on the Rights of People with Disabilities:
     “Ensuring that the education of persons, and in particular children, who are blind, deaf or deafblind, is delivered in the most appropriate languages and modes and means of communication for the individual, and in environments which maximize academic and social development.”
     Thank you from JJ Jones

147. We are a hearing world. Children with hearing loss live in a hearing world and need to be exposed to verbal language. If they remain in a sign language educational setting, each year their vocabulary will fall farther and father behind. The average high school graduate from a school for the deaf reads at a 6th grade level. Where are they going to get a job that will support them with language skills at that of an elementary school student?

148. I am grateful for the draft policy created by the U.S. Department of Education (DOED) and the U.S. Department of Health and Human Services (DHHS) regarding inclusion of young children with disabilities in high-quality inclusive early childhood programs, and I hope this becomes the required policy immediately.
     All young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations.
     The policy provides a concise yet detailed overview that includes both the literature and legal foundations support for inclusion and linking it to that IDEA requires individual decisions and the healthcare systems and supports. This process must incorporate fundamental change in the way a school community supports and addresses the individual needs of each child.
     “Inclusion” does not simply mean the placement of students with disabilities in general education classes. Effective models of inclusive education not only benefit students with disabilities, but also create an environment in which EVERY student, including those who do not have disabilities, have the opportunity to flourish and learn acceptance for ALL.
     Children without disabilities in an inclusive environment can learn compassion, patience among many others. This is a necessity, our school systems are currently failing our children.
     When we believe in children and focus on their capABILITIES they can accomplish great things!

149. While I applaud the support that all children have the opportunity for inclusion when appropriate, this document must still acknowledge and support the individual needs of every child to be the basis for all educational decisions. We know from research (C. Yoshinago- Itano) that young children who are deaf or hard of hearing can achieve mastery of a first language when provided a program that is specifically developed upon their unique linguistic needs by highly trained, highly skilled and well experienced professionals in the field of educating deaf and hard of hearing children. These professionals have a very unique skillset and these specialized programs are typically very unique, highly intensive, and do not resemble most early childhood classrooms. When children who are deaf or hard of hearing receive appropriate early intervention and early childhood education they are able to develop fluency in a first language which leads to full inclusion in education and society. Without developing language fluency in their early years, research shows it is likely a child will remain linguistically challenged his or her entire life. This is turn will hinder a child’s ability to be successful in education overall and in being successfully employed . Please ensure this document will support the individual needs of these children so they can become fully included in education and society.

150. Throughout my childhood & adolescence, I experienced different kinds of schools – early childhood program for children with communication disabilities (kids with speech disabilities, deaf and hard-of-hearing kids learning & speaking the English language, and others) from infancy to 4 yrs and the teacher herself was semi-fluent in ASL. Then I was placed to a school for the deaf (total-communication/sign language-based educational curriculum) from 4-13 yrs old and then graduated from a public high school (with a sign language interpreter).

     Now, as a deaf father of two deaf children who attended the early childhood education program at Kendall Elementary on Gallaudet University’s campus, I couldn’t be more grateful for that program. The teachers, aides, and specialists (speech, physical & occupational therapists) were fluent in ASL which research shows that it is absolutely necessary for the early language acquisition & emotional/social development for young deaf children.

     Even though I do support the concept of including young children with disabilities in early childhood programs, the problem with this policy is that it neglects the fact that many early childhood programs – other than the ones in deaf schools – in the U.S. do not have teachers who are fluent in ASL and other children who are also deaf. Interacting and communicating with other children using the same language is the key to their early upbringing. I believe and many would agree that deaf children would not succeed in these programs where teachers have to depend on “educational interpreters” to communicate with them and with other hearing children who are not even ready to learn & communicate with them in ASL. This would result in feelings of isolation and stunt their emotional & social development. Besides, this would also require frequent evaluations of the interpreters’ qualifications which can be a thorny issue to wrangle about with the program’s school district.

     Having direct ASL instruction with deaf children is usually the most effective approach – so would the early childhood programs hire teachers who are fluent in ASL when they enroll new children who are deaf? Being realistic here, school districts probably wouldn’t due to budget/economic restrictions – so as a result, deaf children would get the short end of the stick which is very pervasive within the deaf community regarding other accessibility issues (VRI, movie captioning, etc).

     So, in other words, this policy may be work for other disabilities, but not for deaf children where direct ASL instruction is the key to their academic development & success.

151. As a parent of Hard of Hearing 5 year old twins, I have seen the vast difference between specialized education and inclusive. I am in favor of an inclusive educational environment, but only once children get older. My children attended a regular daycare until they were 7 months old. The daycare was great, but they did not know how to deal with children with hearing aids. We moved them to a Deaf school and the difference was immediate. The kids have since attended a couple of different Deaf programs (we have moved). They have greatly benefited from learning about Deaf culture and learning ASL. I do not know if my kids will lose more of their hearing, but because they are learning ASL, I am not worried about it. The Deaf community is wonderful, but if you do not know ASL, it makes it difficult to communicate. ASL has helped my children understand English more, and helped them to adapt to different environments (loud/noisy environments). It is extremely important that the Deaf community be consulted before anything is published.

152. Many disability groups might support this draft because they and their parents want them to have equal experience and education with their peers. However, as for Deaf children, it is not so much about having a physical disability, or a mental disability, but a language barrier. Deaf children should have the right to communicate in their natural language – ASL (American Sign Language), and for that to happen for many Deaf kids, the Deaf schools should remain as an option for all Deaf kids. It is not right to force interpreters to be their only language model and person to communicate with. They should also have the right to have peers and teachers who speak their language and understand their culture. My recommendation is that full inclusion be OPTIONAL and a right for any student. Not forced. Allow the parents, school district, teachers, LEA, etc. decide on a case basis what the LRE (least restrictive environment) is for the student, and add that parents and the student has the right to receive full inclusion. Deaf children need a strong first language (L1) being ASL, to boost their second language (L2) English, and that has been proved to be true from many years of bilingual education. The hearing teachers and peers could, although not required, learn basic ASL, but the only language model and person they can communicate with would be the interpreter. Is the interpreter responsible to teach them ASL? No. There is no first language education for them, so they would be delayed while they work on their speech skills IF it is ever successful. Deaf children must have the basic right to be able to communicate in ASL, and there are LRE considerations to be put in place, including their social well-being, language development, and a sense of belonging. Forced full-inclusion for all Deaf kids would be tragic, dangerous, and cause more isolation for them, and in many cases, more restrictive environment. This will backfire for Deaf children, unless they are exempt from the bill and have language rights.

153. Without a doubt, inclusive early childhood programs for children WHO CAN HEAR and naturally communicate via the spoken English language is logical, research-based, and should foster an appropriate education in the least restrictive environment. However, for the child who is DEAF or HARD OF HEARING, one must question whether or not we are addressing their strength (being primarily a visual learner), or their weakness (being unable to hear and resultantly lacking a full, meaningful access to the English language).

     Communication involves SHARED meanings. Without deep, consistent, and meaningful communication with parents, siblings, peers, teachers and other significant people in the child’s life, there are no SHARED meanings, no shared experiences, no development of identity, and inadequate transmission of world knowledge. Deep, consistent, and meaningful communication is a precursor to language development, whether it is a visual or an auditory language. The question that must be raised regarding and placement options is whether or not the child is PRIMARILY a visual or an auditory learner–Does the child best access information and language through the visual or the auditory channel? The answer to this question will address the child’s ABILITY, not his/her perceived DISABILITY.

     Children who are deaf should be afforded the human right of being Deaf, of establishing an identity of which they can be proud, of having a fully accessible language that can lead to literacy in the English language, and allowed to dream and realize their dreams even as their hearing counterparts are encouraged and allowed to do.

154. I already scrubbed my eyes… I couldn’t BELIEVE this kind of nonsense draft! STOP… PERIOD! You guys go to school and learn about the Deaf Culture… What is the heck matter with you guys at DOE?

155. This idea of “inclusion” for many DEAF children is isolation. In an “inclusion” class they are often the only student who cannot hear. They don’t hear the teacher talking, they don’t hear other students talking. There is no incidental learning taking place and very little direct learning taking place. They miss the relationships that are formed in the educational environment. Or they are provided with an interpreter – in pre-school? Yes, often so. This gives the impression that they have equal access to their education but it is not equal access. They are just learning language – they often don’t have enough language to utlize and interpreter. They don’t even know what an interpreter is – children naturally communicate directly, not through another person. This denys them the opportunity to communicate directly to their teacher, and denys them any opportunity to communicate with and learn from their peers. Early intervention for students who are deaf, deaf-blind and hard of hearing needs to include specialized attention to language learning including many opportunitites for visual langauge models and tactile language models. Because deafness is a low incidence disability very few teachers are trained in the specialized langauge needs of these students. Teachers in “inclusion” classes, even general special education teachers, often do not understand the unique language instruction needed for this low-incidence population.

     Special guidance has been provided by OSEP informing the public that IDEA guidelines for LRE are different for some children who are deaf and hard of hearing. This is important guidance that unfortunately is like an asterisk * to the law that few people read or follow.

     Please don’t make the same mistake with this policy for younger children. For those babies who are deaf, deaf-blind, and hard of hearing appropriate language learning is the critical to their preparation and success in school. This bill serves to undermine that opportunity for success for children who are deaf, deaf-blind, and hard of hearing.

     Don’t generalize policy. Keep special education INDIVIDUALIZED. America CAN handle that. Teachers CAN handle that. This is not what is best for ALL children and those who are deaf, deaf-blind, and hard of hearing get marginalized and shorted when policies such as this are released to the public.

     “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

     • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.
     • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

     • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

156. Focus on child’s needs FIRST is the key to success; therefore IEP is a sufficient policy. While I can understand other disability group’s concerns about excluding them from the society, however this policy is trying to drag other group, like deaf into ” one size fit it all”; at whose expense?

     Researchers have shown that earliest language acquisition will benefit children though-out their lives; therefore language rich environment, sign language and bilingualism approach is the answer for deaf children. The new policy will create an impossible undue burden for local schools to provide this; especially that it will be considered a language deprivation if it ‘s not met. It can be considered a human right violation. What about social interaction? Who will be responsible for this? There are deaf people who have uncomfortable childhood experience due to the pain of isolation and loneliness they experienced due to lack, limited or/and poor language access; sign language at their neighborhood schools. It is no secret that people who are socially isolated tend to be at greater risk of health issues. Who’s responsible for these negative outcomes? Schools that provide language rich environment due to large group of deaf students will contribute to a positive self-concept.

     Schools that provide bilingualism environment have higher academic achievement in later years than do students who don’t.

     The draft policy is poorly written as it will open a floodgate to definition of “high quality” and create more complications of the meanings of this new policy. It simply adds more layers and confusions therefore no need to have this draft policy in place.

157. As a 6th grade in-class resource teacher in an inclusive public middle school, I strongly support the policy document calling for more inclusive pre-school education. I work with older students, and I see the benefits of early inclusion.
     My job is to work with regular education teachers to provide appropriately differentiated instruction to classes of diverse talents and abilities. Students with disabilities – some severe – are assigned to regular ed. homerooms and take all classes with their typical classmates. Moreover, during classes, we work very hard to make every lesson inclusive — a class is not “inclusive” when students with disabilities are sitting in the back of the room, doing another activity.
     Students come to our school from inclusive and non-inclusive elementary school settings. It is remarkable to see the changes that often occur in students who arrive from non-inclusive settings. They become more confident and develop their social skills. And, they blossom academically. There is an unfortunate misconception that inclusion is mostly about social and emotional growth, but well-designed differentiated instruction spurs academic growth in all students. Yes, providing this instruction is hard work, but it is worth it.

158. I would like to echo the sentiments of others, that “inclusion” in the typical sense may not be appropriate for children who are deaf. While it may be possible for a predominantly hearing school to make accommodations so that a child can understand and communicate with the teacher, it is not possible to make accommodations so that the child can engage directly with peers. This means students miss out on much “incidental learning,” the kind of learning that happens naturally during casual conversations. This also means that students have frustrated social relationships. Imagine having a 50 year old woman interpreting or providing CART services for you as you ask a boy out on a date for the first time, or at the prom. Much learning in schools happens through peer to peer interactions, and mainstream schools are ill-equipped to accommodate this kind of learning.

     Inclusion often entails that deaf students use a sign language interpreter. By definition interpreters are hearing people, and some estimates suggest that 90% of interpreters have learned sign language as a second language. Because deaf students in mainstream settings are often primarily or exclusively exposed to sign language through their interpreters, this means that deaf students have to learn sign language from a non-native signer. As others have said already, this puts deaf children at great risk for language deprivation.

     I would argue that the least restrictive, and most inclusive approach for deaf children is an environment where they can communicate with teachers and peers freely and directly, not mediated through interpreters, transliterators, of CART providers.

     I hope that you consider amending this document to make special consideration of what an inclusive environment is for a deaf child.

     Best,
     Naomi K Caselli, EdM, MA, NIC-Master
     PhD Candidate
     Department of Psychology
     Tufts Universtiy

159. I am the Administrator for the Idaho Educational Services for the Deaf and the Blind. We serve the continuum of services for students, birth to 21, and including a few specialized preschool programs for deaf and hard of hearing students.
     Early intervention is critical for Language and social development and building a foundation for future educational/career success. Not recognizing that the Least Restrictive Environment (LRE) is one that actually surrounds the student with peers and qualified staff who can communicate and model language in a natural educational environment is a significant shortcoming of this policy.
     In providing for the continuum of educational services, one cannot ignore the value and identification of specialized schools and programs for deaf and hard of hearing children is “inclusion” because they include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families.
     Why is it in “general” education, we seek out “highly qualified” certifications for teaching Math, English, and History, and work hard to make sure that students are placed in classrooms led by such individuals, however fail to recognize those who carry certifications in working with specialized populations, like those who are deaf or hard of hearing, as being “highly qualified”? Furthermore, this policy works to push students away from such highly qualified educators, when they need them most…. at early intervention.

160. Not all children with different disabilities will fit in one school for education but be placed in the right schools befitted for their different special needs. For instance it doesn’t fit to place both Deaf and Hard of Hearing (HoH) children with Deaf-blind (DB) for their needs are vastly different. Others with mufti-handicapped children wouldn’t work too well with Deaf and HoH for their needs, again. There are far different in their needs as well so please place each category of those handicapped children in the right areas for their needs specially! i

161. Hello!

     I wish to thank you for your effort to create the atmosphere that could be more inclusive with the children with Disabilities. Unfortunately, with this draft policy, I am opposed to The Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education because of several reasons. I will outline the reasons:
     1. Over 90 percent of deaf and hard of hearing (d/hh) children born to the hearing parents. This mean language delay in d/hh. The language is so crucial in the early childhood years. The law that protect the d/hh and their parent known as Individual with Disabilities Education Act (IDEA). More states are adopting early hearing detection to ensure the intervention by the service providing and resource available to the early childhood who is d/hh.
     2. The language acquire is so important to the d/hh early children. In massive of researches have proved that American Sign Language (ASL) has been successful and the idea of inclusion would restrict the early d/hh children from enjoy the rich enrichment environment with the use of ASL.
     3. The inclusion idea would mean that the opportunity of professional who is deaf/hh be thwarted from employ themselves with the d/hh children.
     4. I do concur with Barbara Raimondo’s comment about this policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.
     I think a lot of professionals in here have share their thoughts. I personally feel that the Dept. of Ed. do not realize that Deaf education have been around since 1817 and so many deaf children enjoy the access to Sign Language and the schools for the Deaf have been the blessing to the d/hh early children for so long. Why do we need this policy when there are laws that created to protect the right of the early children who are d/hh to engage their learning in the positive environment? This policy draft does not have any given thought on the d/hh children.

162. It is hard to know how bad it would have been to be separated from kids without disabilities. Because I have been included 31 years my life with Down syndrome. Thank you for this stuff you are writing for the United States of America. I like it a lot. It makes sense. Abbey Heins

163. The OSEP draft policy is inconsistent with IDEA, Least Restrictive Environment provisions, specifically Section 612(a)(5) of the Act for a public agency to restrict the placement options for children with the disabilities. Section 300.115, consistent with Section 621(a(5) of the Act, requires each public agency to ensure that a continuum of alternative placements is available to meet the needs of children with disabilities. A continuum of options allows the child to be served based on their individual needs, not the place. One size fits all is not individual.
     Full inclusion doesn’t give our children opportunities it limits their opportunity to one- sink or swim!
     If a child can be effectively integrated, based on their individual needs, then this option is available to them along the continuum. We need to implement IDEA as written-it protects our most vulnerable children.
     There are many longstanding early childhood providers that offer the full continuum of options for children, based on their individual needs. Children move along the continuum with necessary supports to ensure they are successful. Such programs have demonstrated expertise and good measurable outcomes for children. They are not “segregated”, nor does IDEA use the word segregated
     Research and efficacy studies don’t only speak to “inclusion” as being the best and only option for children. There are equally as research and scientific studies demonstrating the early one intervenes with quality programming and servicing the better outcome for the child-the research doesn’t indicate this can only happen in one place.
     Placements along the continuum are currently determined by the child’s local school district, programs and services are based on the individual child’s needs, the first consideration being the regular class. The school district professionals, in tandem with parents, make decisions based on the individual needs of the child.
     OSEP needs to enforce the existing law if this is not occurring in all States, rather than limit appropriate options for children.
     No one is opposed to equal access to quality high programs, rather opposed to no choice for what is appropriate for the individual child.
     There is an enormous amount of work still to be done in defining a high quality program. For example,teacher certification along with training in both early childhood and special education needs to occur before OSEP could begin to think about one option for all. The requirements vary not only across our States but within each State. Equal access needs to really be equal.
     Enforce the provisions of IDEA, support the continuum of options in the least restrictive environment for children based on their individual needs.

164. In this draft, in the section under legal foundations, the statement

     “For children ages three through 21 services are to be provided, to the maximum extent appropriate, in the least restrictive environment (LRE) which includes a continuum of alternative placements and supplementary services:

     can be found. In thirty five years of working with people, children and adults, I have seen this statement chopped in the middle, and the phrase which includes a continuum of alternative placements and supplementary services” ignored. Just as in standardized assessments, one size does NOT fit all. Inclusion that meets the need of a specific child regardless of disability and does not prevent the learning of others in the placement is a wonderful process. Inclusion that ignores the needs – academic, social, physical, linguistic, emotional – of the student with a disability or denigrates the needs of the typically developing students or other students with disabilities is NOT in the best interest of anyone.
     A goal of 100% inclusion is itself discriminatory because some students will lose the opportunity to develop skills that can best be met in a more restrictive environment.
     My own children are DEAF. They were educated in a variety of settings depending on where our government sent my military husband. At various points in various locations they attended schools for the deaf that included an ASL fluent classroom of peers as well as a fully ASL fluent faculty and staff, a self-contained classroom with a teacher fluent in Signed English in a school with a program for the deaf, and a full inclusion situation with an interpreter. When they were in classes with no linguistic peers, their language development suffered. Sometimes, when they were in a deaf classroom, their academic development suffered. One of my son’s issues interfered with the learning of his classmates, so alternatives were put in place so that both he and they could learn. I appreciated having a spectrum of placements so that my own children’s needs were met according to their own specific issues. Please emphasize that any placement discussion must include a spectrum of choices so that a truly INDIVIDUALIZED education plan can be written to meet the needs of the student with disabilities as well as respecting the needs of the others in those placements.

165. I am writing as a deaf adult, retired college professor from National Technical Institute for the Deaf (NTID), parent to four hearing sons, and active member of the deaf community.

     People generally assume that being included in our society is a desirable objective. However we need effective communication and effective access to one another is the key for this to be successful. Another assumption people have is that the earlier one is introduced to the general society the more likely the person will become a full functioning member. There are fallacies with these assumptions. First of all, in the case of deaf people and deaf children, we must have visual communication from birth in order for our brains to develop normally, picking up language is so critical to the development of all areas especially regarding logical development and thinking skills. Deaf children are deprived of this when forced to a) be in a mainstreamed classroom setting in the name of inclusion, b) in an home environment where no one is proficient in American Sign Language and child is forced to speech read or use oral communication, and c) dependent on interpreters and other supportive staff for inclusion. Learning and obtaining access via interpreters is akin to second-hand information. While it is okay every now and then to learn via second-hand, deaf children are subjected to this all the time when in an inclusive environment. Thus the quality of true deep and meaningful learning is not present for deaf children in these mainstream settings. There are countless of studies showing that deaf children born in deaf families are on par with hearing children in brain development. What I believe is best is a system that waits until a deaf child has developed full native (ASL) language strengths before entering an hearing educational environment. Otherwise these children have such serious language delays. Studies show children must have at least one strong first language before they can master a second language. For deaf people that language is ASL. We need a visual language first before we can move forward to master English. This policy does not take into consideration of the needs of how deaf children best learn. One size does not fit everyone.

166. This policy would work well for children with disabilities, but it will not work well for many Deaf children. Deaf schools or Deaf institutions greatly benefit many Deaf children’s education and social interaction. What makes Deaf children different from other children with other disabilities is that Deaf people have their own language – American Sign Language (ASL). Using ASL as an instructional language in Deaf education successfully enhances Deaf children’s literacy skills. Deaf institution is the best place for many Deaf children’s education. ASL is a beautiful language – Deaf people’s language. We believe that the U.S. Department of Education and the U.S. Department of Health and Human Services should respect and support cultural diversity, too. We are asking the departments not to include Deaf children and Deaf education in this proposed policy. We are asking the departments to put their best effort in supporting to prepare many Deaf children for Deaf institution in their early ages. ASL programs in early childhood programs for Deaf children will significantly benefit Deaf children’s education. The most important point the departments need to understand is that the word “institution” is a positive word for Deaf people because institution is where Deaf students share their own culture. Again, please do not include Deaf children in this policy if ASL benefits their education the best.

167. For heavens sake, physical inclusion does not automatically equate a genuinely inclusive environment and placement. Only if the child has the fundamental yet critical and indispensable access to language, communication and people in and out of the classroom – access that hearing children routinely experience – can we truly say the child is receiving an inclusive education.

     The Special Education population is incredibly diverse as a whole and within each “disability” too. To push for inclusion by way of physically placing the “Special Education” child with the “non-disabled” for ALL special education children is blatantly a “one size fits all” approach and in damaging violation of IDEA’s core principle: that every individual child is unique and placement must be based on what is right and best for that particular child.

     A full continuum of placements and recognizing must exist – for humane and educational reasons.

168. I would like to begin by applauding this effort. The policy statement is well crafted and highlights barriers to providing inclusive opportunities for young children as well as potential solutions, which honor local decision making. Well done!
     While I agree with the entire policy statement, I would like to highlight areas of particular support. First, I would like to address the recommendations that states ensure that quality frameworks focus on inclusion, that they ensure state policies support high-quality inclusion, and that they implement support for social / emotional and behavioral health. Many states have implemented quality frameworks as a part of Race to Top, or for overall quality assurance. While I support measures which are focused on improving the overall early childhood education experience of young children, I have seen that very few include indicators of high-quality inclusion (such as adherence to a child’s IEP, following individual behavior plans, etc). The addition to such indicators would provide a layer of support to ensure that programs understand the importance of meaningful inclusive opportunities for young children. Additionally, many advocates of inclusion find state funding formulas and policies to be counter-productive to providing inclusive opportunities for children under Kindergarten age. I am thrilled to see the emphasis on social-emotional and behavioral health. Social-emotional competence is a critical factor for future success.

     My final comment is concerning the role of early interventionists, special educators, and related services personnel. The emphasis in not only using evidence-based practices with children, but also in using evidence-based consultation and coaching models is critical to ensuring positive learning outcomes for children.

169. The National Association for the Education of Young Children (NAEYC) is the world’s largest organization working on behalf of young children. NAEYC promotes high-quality early learning for all children, birth through age 8, by connecting practice, policy, and research. We advance a diverse, dynamic early childhood profession and support all who care for, educate, and work with and on behalf of young children.

     NAEYC has long advocated for building high quality and inclusive early childhood programs. Our 2009 position statement on inclusion, (see http://www.naeyc.org/files/naeyc/file/positions/DEC_NAEYC_EC_updatedKS.pdf)) prepared in collaboration with the Division for Early Child Development (DEC), lays out many of the ideas that are greatly amplified in this joint policy statement. In particular, the focus on access, participation, and support, introduced in the 2009 statement, are resonant within the draft policy statement. These ideas are also central to the NAEYC Code of Ethical Conduct (see http://www.naeyc.org/ethics), for example: (I-1.8) —To support the right of each child to play and learn in an inclusive environment that meets the needs of children with and without disabilities; and, (I-1.9) —To advocate for and ensure that all children, including those with special needs, have access to the support services needed to be successful. They are further built into NAEYC standards for programs serving young children (see http://www.naeyc.org/academy/primary/standardsintro). In short, there is a history in early childhood of talking about inclusion. This policy statement challenges us to put that talk into deeper action.

     The policy statement captures many of the challenges that we already anticipate in building high quality inclusive opportunities for children. The statement puts new urgency into solving these challenges. It comes about at an important time for early childhood education, as calls for increased access continue across the country. The result, as evidenced in many states over the past year, is managing how we grow both access and quality, and how we do so to ensure equitable access, participation, and support for children with disabilities and their families. We need to make the investments that ensure appropriate physical environments as much as investments for appropriate and effective preparation and support for early educators to meet the needs of all children in inclusive settings. We must build systems for screening children and following-up to determine what specific needs children have and how to make appropriate opportunities available to them. We must also continue to work towards a fully functional early childhood system. As this policy statement anticipates, there needs to be coordination within states across agencies and programs. In addition, the policy calls for clear guidance and coordination across the various federal entities whose regulations, policies, and procedures must align.

     NAEYC is encouraged by the breadth of this proposed policy statement, and the depth it gives to not only valuing inclusion but in actively working towards inclusive early childhood programs.

     • thank you!

170. The benefits of Inclusion on typically developing children I believe is enormous!! Especially in Pre-School. The benefit, empathy and compassion in the typically developing peers. This is huge!!! Empathy is missing in our society. Children need to learn that we are a melting pot, filled with wonder and difference.

171. I write as a recipient of the National Research Service Award from NIH/NIDCD for my studies of cognitive development in deaf children with and without early exposure to sign language. The evidence from well-controlled research studies fully supports the lived experiences of the many Deaf individuals who have commented here. Although full inclusion may benefit some people with some disabilities, the unique circumstances of early deafness merit special consideration. Deaf children who learn and use American Sign Language as their primary language are NOT well-served by being “included” in a mainstream environment where neither peers nor role models share their language. It is far more INCLUSIVE to allow these children to flourish in an environment where their language, ASL, is esteemed and shared.

172. As a Deaf adult of 5 hearing CODA children I am opposed to this draft.

     Inclusion works for DA kids who have hearing and speech abilities. Deaf and HOH DA kids tend to fall through the crack.

     As a person who experienced ‘inclusion’ during the 1960s 1970s – it totally doesn’t work. As a mom of a child with IEP – I can see the difference. My child hears, I do not.

     PLEASE – be very specific with bills like this.. DEAF and HOH kids need to be considered outside of the general DA realm which has a ONE SIZE FITS ALL mentality.

     Education relies on information being received and understood.

     Most mainstream kids have interpreters who are UNQUALIFIED and California changed that 10 years ago. It took TEN YEARS to bring their education Interpreters UP TO PAR.

     So USA is in no position right now to required INCLUSION for Deaf and HOH kids.

     I OPPOSE this bill and my heart bleeds cuz we Deaf and HOH people are so often overlooked and ignored.

173. Strongly disagree when it is involved with hearing impaired, I am Deaf and have a strong deaf family and was able to see the different when some of my deaf family whose went to special school for being deaf and another of my deaf family whose went to deaf school. A huge different in education and a huge different in communication. The one who went to special school has delayed learning due to not having strong deaf society and teachers. They had to learn from another family who came from a deaf school. We does not belong to inclusion because we are not really in need for a special need but a american sign language are all we need for a better communication and access to same deaf community. Being a deaf child is better in learning by a signing teacher so the child would not feel left out and feel all comfortable when a child see another child signing as well. The key to deaf community is having the group of signing together and feel being welcomed in the deaf world. Deaf school already have those programs and acknowledge of what to do with deaf children. They have the program provided already. Inclusion should be to who need it the most such as requiring special equipments access or in one on one teaching time. Being deaf in a deaf school is not diffucult to learn because they are related. Please consider this and remove deaf/hard of hearing from this category. Thanks for your time.

174. Inclusion won’t benefit deaf and hard of hearing children because it would only cause language deprivation in children. The deaf and hard of hearing children needs to be in environment where their natural language is exhibited continuously, not only that they learn their culture, how to overcome their barriers in reality upon graduation. We have everything to give for our deaf and hard of hearing children while public schools only come across ONE deaf child on average once in 7 years. How is that possible to qualify the school to give preparedness for our deaf and hard of hearing children? This policy statement is not needed as The Americans Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. The word “inclusion” is not anywhere in the law. This draft guidance misinterprets the law and causes confusion.

175. As a child who was mainstreamed in the 1970’s , being deaf is not easy, will being included mean interpreters will be there to help communications with fellow students as well as teachers and others? Deaf and Deaf-Blind require a lil different approach to education then other disabled people.

176. For the Deaf population, “inclusion” can have very negative effects. The belief is that students with disabilities, which includes deaf students, need to be in environments with typical peers so they have strong models. Deafness is not a cognitive disability. It is a language barrier. By putting deaf students who use sign language for communication in classrooms where spoken language is the source of communication, then the student does not have access to strong models. It is not supporting the child, but rather hindering their development because they don’t have access to equal communication. They don’t have language models other than one interpreter who interprets instruction, but most likely not social interactions. For these students, putting them in spoken communication environments with an interpreter is a restricted environment. Strong language skills are needed for learning academic content. Having inadequate or insufficient models for language will inhibit the deaf child’s ability to acquire language and academic skills at the same rate as their peers.

177. the best for the deaf and hard of hearing go to deaf school. Why deaf school ? Because The teacher who are deaf and have also the hearing teacher who knows the deaf culture that can fit and teach to the children’s life and education and learn and can able to understand and feel connect the more for their children ‘s life

     Don’t put in a wrong path with the other disable in the same school or class that aren’t fit together

     Don’t destroy ur kid’s life and their education

178. The National Center for Learning Disabilities applauds the Department of Education and the Department of Health and Human Services for the work they’ve put into this proposed policy statement. Responsible inclusion in general education programs is critically important to the education of students with disabilities. Research has demonstrated the positive effects that inclusion has on both students with disabilities and without disabilities. Equally important is the need to provide high-quality early learning programs for all students. Providing high quality educational opportunities to students during the early school years can often mitigate the impact a disability has on a child later in life and protect the child from the unfortunate but all too real consequences of diminished self-concept because of repeated frustration and failure. Therefore, NCLD strongly supports the inclusion of students with disabilities in high-quality early education programs. While we work to expand access for all children to early education programs, we must also ensure that programs and professionals have the tools and information they need to identify children who may be struggling with learning disabilities and attention issues and maintain appropriately high expectations for their learning. We must also ensure that, along with our focus on inclusion, high-quality early learning programs put a strong emphasis on supporting young children who struggle and whose disabilities have not yet been identified.

     Students with specific learning disabilities and attention issues – in areas such as reading, math, writing and executive functioning – constitute the largest number of students with disabilities. Yet, because of the “hidden” nature of their disabilities and the fact that they often possess areas of strength that allow them to remain under the radar, they can go unnoticed for years. Careful screening of all children and especially those at risk for learning disabilities and related disorders offers an early window of opportunity for educators and parents to intervene before children experience frustration and failure. At a very early age, children at risk for disabilities in reading, writing, or math often display signs of these challenges. Struggling to grasp early literacy and numeracy concepts and uneven development in the acquisition of foundational skills in these areas can be precursors to learning disabilities such as dyslexia, dysgraphia and dyscalculia. Early recognition of warning signs – even in children as young as 4 or 5 – coupled with well-targeted screening, evidence-based instructional interventions and supports, and ongoing monitoring of progress are critical to preparing children for a success in school and in life.

     Knowing this, it is imperative that early learning programs take a proactive approach to meeting the needs of students who are at-risk for developing disabilities in reading, written expression and math. By screening for possible delays in these critical areas, we can prevent problems before they occur and provide supports for children to ensure appropriate skill development. A comprehensive and meaningful screening requirement and a mandate to ensure the delivery of high-quality professional development services to all school personnel should be part of any high-quality, inclusive early education program. In order to fully include and meet the needs of all students with disabilities, we must also consider and identify those students whose disabilities might otherwise go unnoticed for years.

179. Deaf children should not be included in this disabled children mix. Children with different disabilities other than being deaf can benefit from this program. Deaf children’s needs are different and that is communication based. So please understand that deaf children need to be placed in a different setting, preferably at schools for the deaf or programs for the deaf where there are no communication barriers.

180. Reading all these comments – one thing I noticed and have to emphasize is that the policy statement should NOT ‘lump’ all disabilities under one umbrella. All other disabilities other than deafness have access to language through multiple channels. Inclusion assumes that children with disabilities are being included but that is not true – it can instead result in isolation. The only disability related to deafness is how they acquire language and this policy does not take in consideration how language acquisition is done with deaf/hh children. Language benchmarks for d/hh children as well for other children with disabilities should be conducted every 6 months and based on those results, a continuum of options is the best approach for ensuring that these children are served appropriately.

181. I am grateful for the draft policy created by the U.S. Department of Education (DOED) and the U.S. Department of Health and Human Services (DHHS) regarding inclusion of young children with disabilities in high-quality inclusive early childhood programs, and I hope this becomes the required policy immediately. The policy provides a concise yet detailed overview that includes both the literature and legal foundations support for inclusion and linking it to that IDEA requires individual decisions and the healthcare systems and supports. High quality programs that include most restrictive environments will not only save money but will improve outcomes for everyone in the long run. All young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations. “Inclusion” does not simply mean the placement of students with disabilities in general education classes. This process must incorporate fundamental change in the way a school community supports and addresses the individual needs of each child. As such, effective models of inclusive education not only benefit students with disabilities, but also create an environment in which every student, including those who do not have disabilities, has the opportunity to flourish. Children without disabilities in an inclusive environment can learn compassion, patience among many others. This is a necessity, our school systems are currently failing our children.

182. First, Deaf and Hard of Hearing children are much different from other people with disabilities. Yes, they are disabled due to hearing loss. The only difference is – language. Instead of having the inability to hear spoken English, they rely on visual language. The visual language could mean American Sign Language (ASL), Cued Speech, Oral, and many more. This does not mean their (deaf/hard of hearing children) ability to acquire language acquisition is much different from the mainstream (hearing children without disabilities). With all rhubarbs going on around here saying children with visual language will infer their ability to listen and speak phonetically.

     My sons do have hearing loss. Eldest son has unilateral hearing loss while the youngest has bilateral hearing loss. (Unrelated to this, they both do wear cochlear implants.) They were exposed with Sign Language at early age (since birth) and their language acquisition with American Sign Language and English are exponentially advanced when comparing with other mainstream children at their age in mainstream (Under US Department of Education’s but not from Office of Special Education and Rehabilitation).

     Often, I’ve been approached by other parents whose were very impressed with my children’s languages (comprehension and ability to express) and inquired how did they get to be “so much more”. I’ve often responded them with this, “I offered them the access to language acquisition at very early age, and worked with their listening and speaking (English) at later age. Listening and Speaking is considered as skill, but not the language. They (boys) needed language from the start, and easily absorbed any other skills.” My boys are living proof of what the current system/perspective on how to educate deaf/hard of hearing children is broken, as of “not working at all”. It’s all because we (the parents) decided to give them the access to the language acquisition by providing them a way where they can easily understand and communicate with before offering them to practice on the skill of listening and speaking.

     The inclusion you are proposing will be damage Deaf/Hard of Hearing children’s language acquisition and their education.

     Second, Deaf and hard of hearing children suffer from language deprivation when they are placed with hearing children with lack of full resources to ensure language access (qualified interpreters, teachers knowledgeable about visual aspects of bilingual learners, accessible technology like captions, flashing fire alarms)- and it would be both an impossible task and an undue burden for every early intervention environment and early childhood education classroom to provide the above simply due to deaf children being both unique in their language abilities and being a low-incidence disability group.

     Third, this policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. Also, the word “inclusion” IS NOT ANYWHERE IN THE LAW- This draft guidance misinterprets the law and creates confusion.

     Fourth, Deaf and blind children have unique resources in state schools and large mainstream programs that are absolutely necessary for a majority if not all of the same children due to the access to qualified professionals who are trained and experienced in working with deaf and blind children and their families. On average, a public school teacher sees a deaf child once every 7 years- so how can teachers prepare for this occurrence, much less an early childhood program which are already provided by numerous deaf-specific programs. This policy paper will destroy those hard-working schools and programs which have worked for years to build up knowledge and expertise to ensure our deaf and blind children have the best language foundation. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers.

183. I want to thank the U.S. Departments of Education and Health and Human Services for the policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. I support this policy and hope it will be officially released as soon as possible. The clear message in the policy statement about the benefits of inclusion and the resources provided in the appendices will help me as I advocate for my child. The recommendations for state and local education agencies will help change the system, so it is not as difficult for parents to find inclusive early childhood programs or as difficult for our children to be successful. An especially important recommendation is the inclusion of children with disabilities in proportion to their presence in the general population (natural proportions). The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond.

     As the parent of a two year old with Down syndrome I feel that inclusive education is very important. I am already concerned because our local public school does not provide an inclusive preschool class. Currently we will have to choose between a private community preschool that will not have special education staff to provide support that our daughter may need or a class at the local elementary school that consists only of students with disabilities or delays. I feel strongly that the public school should have and support an inclusive classroom. I hope that this policy would encourage schools to really look at the general education classroom with supports as the first option for all students with disabilities. I do believe that inclusion is best for most all students but that a continuum of options should be available and that each students needs will be met in the most appropriate setting for their individual needs.

184. of course inclusion is best dummies! better quality for all.

185. Full inclusion should be the goal for all children wherever possible. Children who are deaf and learning to listen and talk (using assistive listening technology) are able to mainstream. While I would caution that there is a period of intense intervention needed the goal of full inclusion is possible. We are seeing that greater than 90% of children who have appropriate early intervention are able to enter the mainstream by kindergarten and compete on par with speaking and hearing peers with minimal if any support.

186. I believe there should not be a “one size fits all” policy on inclusion. Such policies will inhibit children/students from being served appropriately. Policies should adhere to the law and should only state that LRE/Natural Environments and placements that are approved by the IEP and IFSP Team should be considered. The law ensures that ALL students are served based on their individual needs. This proposed policy is trying to push one placement over another. This decision belongs to professionals and parents and is not OSERS responsibility. There are many children who would not fare well in an inclusion setting for a multitude of reasons, including but not limited to: severe cognitive deficits and speech-language disorders, anxiety and sensory issues. It is critical, especially in early childhood years that services be provided in the appropriate environment, based on the individual needs of each child. Implementing a policy that forces children to be placed in an inclusion setting suggests that parents are not capable of choosing a “high quality program” when in fact they are the most qualified to make such decisions as they know their children best. Please help to appropriately implement the current law, not set policies that contradict current law.

187. On behalf of our 90,000,member physical therapists, physical therapist assistants, and students of physical therapy, the American Physical Therapy Association (APTA) appreciates the opportunity to submit comments on the draft policy Statement, “Inclusion of Children with Disabilities in Early Childhood Programs.”

     Physical therapists and physical therapist assistants work in early intervention under Individuals with Disabilities Education Act (IDEA) and support families of children at risk for or with disabilities to promote their development, learning, and participation in family activities and routines as part of the Individualized Family Service Plan (IFSP). The Section on Pediatrics of the APTA represents pediatric physical therapist in all practice settings and has special interest groups focused specifically on early intervention and school based practice. Accordingly, APTA has a strong interest in any policies related to children with disabilities and their early childhood programs. We respectfully provide the following comments.

     Physical Therapy

     APTA commends the U.S. Department of Health and Human services and the U.S. Department of Education in the development of this draft joint policy statement. We recognize the importance of quality early intervention program for children with disabilities and their families. The policy statement reinforces the commitment to the implementation of such programs.

     Draft Policy Statement

     APTA recommends the following additions and revisions:

     1. Page 4: APTA commends the agencies’ reinforcement of the IDEA presumption that the first placement option should be inclusion while recognizing a continuum of placement options exist.
     2. Page 5, “Attitudes and Beliefs”
     Ensuring that supports are provided for teachers and classroom staff that increase the capacity to support the needs of all children is also necessary.
     3. Page 5, “Lack of Comprehensive Services”
     Although there are Head Start programs that have been successful, there are wide variations in their administration, coordination and offering of “comprehensive” services.
     4. Page 10, “Ensure Personnel Qualification Policies Facilitate Inclusion”
     Specifying which related service providers are available is important in educating readers of this policy statement. Therefore, “physical therapists” should be added in the following sentence:
     “This should be done in consultation with and under the supervision of professionals with specialized training and certifications, such as speech-language pathologists, physical therapists or other related service providers, special educators, and early interventionists.”
     5. Page 14, “Early Interventionists, Special Educators and Related Services Personnel”
     We recommend the addition of a bullet point that addresses the need for professionals to have the capacity to implement strategies that improve the family’s (and other team members’) confidence, competence and capacity to support the overall development and learning of all children. Team members do not work in isolation and should be collaborating with all team members to share knowledge, expertise, etc.
     6. Page 15, Section 6, “Establish an Appropriate Staffing Structure and Strengthen Staff Collaboration”
     APTA members working with these children appreciate the agencies’ awareness and acknowledgement of the importance of collaboration and allocation of time necessary to do so.
     7. Page 15, Section 7, “Ensure Access to Specialized Supports”
     Add “physical therapists” to the first sentence: “Early childhood programs, schools, and family child care networks should have access to specialized supports delivered by experts like early interventionists, inclusion specialists, early childhood mental health consultants, behavior consultants, special educators, developmental specialists, or other related service providers, such as speech-language pathologists, physical therapists and occupational therapists.”
     8. Page 21, Appendix 2, “Professional Associations and Organizations with Resources to Support Inclusion”
     Add:
     “American physical Therapy Association (APTA) has a practice guide on providing physical therapy services under IDEA:
     McEwen, I. R. (Ed). (2009). Providing physical therapy services under the Individuals with Disabilities Education Act. Alexandra, VA: Section on Pediatrics, American Physical Therapy Association.”
     9. Page 23, Appendix 3, “State-Developed Resources to Support Inclusion”
     Under the sub-heading of “North Carolina,” the following is an additional available resource to consider including:
     North Carolina: NC Foundations is a solid resource (pg. 14 addresses inclusion): http://www.ncpublicschools.org/docs/earlylearning/2013foundations-bw.pdf

     Draft Executive Summary:

     APTA offers the following comments and recommendations:

     1. Page 1, Introduction, second paragraph:
     We suggest the addition of language beyond “should have access to inclusive high-quality early childhood programs” as – in addition to “access” – participation in these programs is equally vital.
     2. Page 2, “The Legal Foundation”
     We support the emphasis that IDEA presumes that the first placement option considered for each child with a disability is the regular classroom that the child would attend if s/he did not have a disability.
     3. Page 3, “Building a Culture of Inclusion,” last sentence:
     We suggest removal of the words “access to” so that the sentence reads: “….is the first step to reaching the ultimate vision of providing inclusive high-quality early learning opportunities for all children.”
     4. Page 4, Section 8, “Implement Statewide Supports for children’s Social, Emotional and Behavioral Health”
     APTA commends the agencies for recognizing the need to have access to specialists who can build capacity. Additionally, consider identifying successful strategies for accomplishing capacity such as knowledge brokering, translation to practice, etc.
     5. Page 4, Section 2, “Early Childhood System Recommendation”
     We recommend including an operational definition of “meaningfully discussed.”
     6. Page 4, Section 5, “Early Childhood System Recommendation”
     We support the promotion of delivery of services in early childhood settings, embedding services into everyday routines, and/or co-teaching or coaching teachers. However, we suggest adding a statement about building the teacher’s capacity to support the learning and development of children with disabilities.
     7. Page 5, Section 7
     The role of experts or specialists in such circumstances should focus on increasing capacity of team members who support the child’s learning and development on a daily basis.

     Conclusion

     The APTA, including its Pediatric Section, supports the issuance of a strong policy statement in support of inclusion of children with disabilities in early childhood programs. The IDEA presumption that the first placement option should be inclusive needs to be reinforced and we commend the agencies’ emphasis on this factor. Ensuring that children with disabilities and their families have access to the necessary early intervention services to promote their development, learning, and participation in life activities is crucial to positive outcomes for these children as they grow.

     Physical therapy services promote the health and development of children at risk for or with developmental delays and disabilities. We commend the HHS and the ED for seeking input from stakeholders who are invested in supporting these children and their families. APTA looks forward to working with the HHS and the ED/The Office of Special Education and Research Services (OSERS) in its efforts to reinforce policy and provide guidance to improve real-world implementation of these policies. Thank you for your consideration of our comments. If you have any questions, please contact Maria Jones, PT, PhD, Federal Affairs Liaison, Section on Pediatrics, at 405-271-2131 x46811 or maria-jones@ouhsc.edu or Deborah Crandall, J.D., Senior Regulatory Affairs Specialist, at 703-706-3177 or deborahcrandall@apta.org.

     Sincerely,
     Paul Rockar, Jr. PT, DPT, MS
     President
     American Physical Therapy Association

188. While inclusion may be the correct option for most children with disabilities, it is not the best option for deaf students who need an ASL rich environment. Lumping all disabilities together in another law (no child left behind) is another mistake.
     I have seen deaf children who have come from inclusion settings over the past 35 years of teaching and would say that everyone lacks many basics due to this inappropriate early beginning in education.
     This is a draft, so I implore you to edit this proposal to allow deaf students to have ASL rich environments rather than inclusion environments.

189. While full inclusion is always the end-goal of a well planned program, there is good reason for the word “Individualized” in the IEP. We know the brain has its greatest plasticity in early years, and for many very young children this offers the opportunity for intensive, though relatively brief intervention that will close their developmental gap and give them the best opportunities for life-long educational success. This is particularly true for children with hearing loss, who need intensive services to address their sensory access and develop language, If this opportunity is lost due to inadequate intensity of service, the resulting language delay may impact their entire life. It is absolutely essential that we maintain a continuum of service provision that will allow children who need it the access to a more restrictive and intensive environment to meet their individual needs and ensure their future access to the curriculum.

190. This sounds great on paper, but I fear this would be a poor choice for some disabled students. My son is Autistic and was placed in with the main stream “normal” children. By third grade he was already two years behind. He was bullied by students AND teachers so badly that he now suffers from PTSD and severe anxiety. I removed him from public school and placed him in cyber school. He is in 7th grade now and is an honor student.
     My point, not all children are the same. Placing ALL disabled children in the same learning environment is a mistake! Teachers do not have the time to work with these children and they fall behind! Each child needs looked at on an individual bases to decide what is best for him or her!
     Thank you for listening.

191. Please consider changing wording in the Executive Summary to align with developmentally appropriate practice. Holding children to high expectations is appropriate, however, these “high expectations” should be developmentally appropriate. The phrase “holding high expectations” can lead to UNREALISTIC expectations for any child, regardless of their abilities.

     “The Departments define inclusion in early childhood programs as including children with disabilities in early childhood programs together with their peers without disabilities, holding “developmentally appropriate” expectations and intentionally promoting participation in all learning and social activities, facilitated by individualized accommodations, and using evidence-
     based services and supports to foster their cognitive, communication, physical, behavioral, and social-emotional development; friendships with peers; and sense of belonging”

192. Please consider the unique needs of deaf and hard of hearing children. Mainstream programs are not the least restrictive environment for these children when they have to communicate solely or primarily through interpreters. Having to communicate through an adult all day long hinders deaf/hoh children’s “cognitive, communication, physical, behavioral, and social emotional development; friendships with peers; and sense of belonging” (to quote from your executive summary). State schools for the deaf provide a communication accessible environment where children can have direct interactions with their peers and successful adult role models. State schools for the deaf and large mainstream programs of deaf students also allow teachers to maximize the numerous cognitive benefits of bilingual education. Please recognize the unique nature of deafness and American Sign Language among the overall population of children with disabilities!

193. I would like to extend my wholehearted support for the POLICY STATEMENT ON INCLUSION OF CHILDREN WITH DISABILITIES IN EARLY CHILDHOOD PROGRAMS. Not only will it increase public understanding of the research and legal foundations but it will provide the comprehensive recommendations and resources necessary for states, LEA’s and early childhood programs to begin to change their systems.
     Including and supporting young children with disabilities in high quality early childhood programs is a critical first step in ensuring their future participation and positive outcomes in school and beyond. I would like to make a few suggestions that would further support and clarify the policy. First, I wonder about the definition of early childhood programs as “those that provide early care and education to children birth through age five, where the majority of children in the program are typically developing.” In many states LEA’s have created special education preschool programs to serve as the LRE for their young students with disabilities. The model provides for one teacher who serves in the role of general early childhood educator and special educator and although inclusive, includes just one more child without a disability. My understanding is that this model meets the federal definition of a regular early childhood program for indicator 6 data collection but does it meet the definition and the spirit of early childhood within the policy statement? Would it be feasible to instead define the “general early childhood” environment , potentially referencing natural proportion instead of majority? The policy clearly articulates the role of the special educator as a support to the child and general educator however I am concerned that the current definition in the policy may be confusing and detract from the overall understanding. My second suggestion has to do with a reference in the scientific foundation section where it is states, “…these desired outcomes are achieved only when young children with disabilities are included several days per week in social and learning opportunities with typically developing peers.” I wonder if this will lead to a literal interpretation of the number of days children need to be included as opposed to recognizing that children with disabilities require at minimal the same dosage as their peers. Finally, you may want to include Rhode Island’s Inclusive Practices tip sheet http://center-elp.org/wp-content/uploads/2015/03/Exceed-Tip-Sheet_Inclusive-Practices.pdf in your state resources. Thank you!

194. Deaf people who use ASL exclusively are a linguistic minority, and they don’t consider themselves disabled.

     If all FAILS, here’s a tip – IDEA favors the whole placement of a child, rather than the educational aspect for the child alone. To maximize deaf children’s education, apply the law section 504 and register ASL as the students’ primary language on the IEP. This clause will force the school to hire certified and educated ASL interpreters.

     An excerpt from my novel, “Deaf Beneath” regarding the LRE mandate:

     Just as the adults took the students to the cafeteria for their lunch, the new principal decided that there would be changes made around the cafeteria. He ordered all the students to line up, take their tray of food, and to sit in one row, single file, rather than pick whichever seat they wanted.

     Once a bench was filled, they had to sit at the next available table. All the students faced the west side of the cafeteria, one row per table; the opposite rows in front of them on the same table were to remain unoccupied.

     That created a problem for the deaf students. If they did not stand together in line, then they would be inadvertently seated separately. Hearing students had their friends on their sides, while the deaf students sat between the hearing students. The hearing students had someone to talk to; the deaf students had no one.

     A hearing boy asked Dalton something. Dalton smiled, played with his food, and made a face. The boy asked him something again, Dalton replied in shrugs. The hearing boy gave up and talked to the hearing boy next to him.

     Joey looked around apprehensively and fiddled with his utensils. The hearing students on his sides were talking to each other across Joey’s food tray. When one of the hearing students said something to Joey, he stared straight ahead pretending to not see the kid talking.

     The cafeteria was loud and the adults on duty wore the microphones and they were reserved strictly for the adults. If the deaf students had them, then the lunch experience probably would have been better. Or have the deaf students sit together, the Deaf row, as Joey would have liked.

     The lunch seating arrangement was inappropriate to the maximum extent of the LRE mandate. Everything that was set up for Joey actually worked against Joey, as it did for most of the deaf students here. He didn’t have the maximum access to information. The deaf students and Joey stared at their peers’ backsides as they ate. The adults on duty were indiscriminately talking into the AEA microphones. The cafeteria walls were absent of posters and banners. In addition, there was a lack of eye contact with anyone in the cafeteria room. Zero input and zero output.

     The disciplinary methods applied at the Deaf schools in the 80’s were somewhat similar to the cafeteria seating arrangement at Knight, the single row table. One of the disciplinary measures at the Deaf schools was that the Deaf students would be placed in an isolating environment such as a dimmed corner, facing against the wall. That’s the basic idea of ‘zero input/output’.

     The Knight principal inadvertently punished the innocent deaf students, by depriving them of input, socially and linguistically.

     I confronted the principal about this arrangement and I reminded him that this single row approach worked well for those who shared one common language. He replied that this was a way to break up cliques and to force others to learn to respect whoever sat with them.

     It was pointless to continue.
     (end excerpt)

     There you go. That’s the LRE mandate for Deaf folks,,,,

195. Edward Scissorhands movie is my all time favorite because it portrays an actual integration attempt that failed badly. This film’s theme pretty much mirrors the LRE mandate.

     Look no further.

196. As a stakeholder in the community, and the mother of the child whose hearing status impacts his ability to access spoken language, I fully support and affirm the concerns of fellow stakeholders in the inherent danger and risk that the language of this policy holds for children who are deaf and hard of hearing. It is imperative that Congress recognizes the critical and fundamental differences in the manifestation of inclusion programs for deaf and hard of hearing children. The needs of this population, primarily related to direct access to education and information and communication, can not be met with the standardized approach proposed. Research continues to support the need for fluent language models for these students, for the visual presentation of information and instruction, and for a strong foundation in the native language of their community, American Sign Language, to ensure students have the opportunity to reach their full potential. What is particularly troublesome is that this policy targets early childhood intervention programs, the time when unobstructed access to language and information is most critical for proper development. It is imperative that the policy reflect the need for parents to have a choice in educational programs for their children, to include options like schools for the Deaf and Deaf programs so that parents have the opportunity for their children to be educated so that parents have the opportunity for their children to be educated in a setting that truely is the least restrictive

197. The Tale of Two Deaf Children
     There are two deaf children. Jill is fluent in American Sign Language because she has Deaf parents. Jack has hearing parents and he doesn’t use ASL. They are 5 years old.
     On the first day at a school. Jill has large vocabulary and great knowledge. She is able to express herself well. She fingerspells words. She has high self-esteem. Jill grew up from infant in home with excellent relationship with her family. There is no lack of communication.
     Jack unfortunately has little knowledge and low self-esteem. His speech is not clear. His family attempts to communicate with him but it is not fully. (Many, not all, parents and siblings today learn ASL later to communicate with deaf child.)
     If they are placed in the public school with interpreter service, Jill is more likely to succeed than Jack because she communicates better. Jack will have a long way to catch up. Jill comes home from school to fully communicating environment while Jack does not until both parents and siblings learn to use ASL. They both face “Light Switch Syndrome.” Light on means communicating well. Light off means no communication like in darkness.
     If they are placed in the school for the deaf or public school with classrooms containing certified teachers of deaf, the educational environment will be much better. Jack and Jill will interact with adults and other children using ASL. Jack will catch up on his language skills quicker. No Light Switch Syndrome.
     So the Rules enforcing total inclusion will create total isolation for students who are deaf. Surgery does not fix hearing! I hope that the Department of Education will consider to keep the continuum of educational choices for deaf, deafblind and hard of hearing children.

     Christopher Hunter
     Former Teacher of the Deaf
     Deaf Person Graduated from California School for the Deaf, Riverside

198. Inclusion has given many students the opportunity to have access to good programming, in schools close to home. That is a wonderful thing. Special Education is about celebrating and meeting the unique needs of each child. IEP’s and IFSP’s are about individual needs. Please do not assume scripting a law to mandate inclusion is right for all children. Some Deaf and HoH children need and thrive in the LRE (Language Rich Environments of a Deaf ) Schools where they are given the language access and education that allows them to be great, fully engaged, culturally proud., amazing, and be with peers. I think inclusion allows many students to be just that-fully included, loved, valued and part of the mainstream. For many of our Deaf/Hh students, the Language Rich Environments (LRE) of Deaf Schools allow that they are fully included, loved, valued, and part of their mainstream. I am hopeful this law will be used to make all of that possible and not return us to the days of “one size fits all”.

199. The definition of LRE implies that a child with a disability will thrive in the most least restrictive environment. For a Deaf child to thrive, s/he needs to be in a setting where s/he is able to access quality communication 24/7. This is the true definition of LRE. The setting will require each teacher, staff, and student to master fluency in sign language in order for the Deaf child to fully benefit from the inclusion. It is not fair to the Deaf child to “wait” for everyone to master the language before the child can be fully integrated. Taking a couple of sign language classes is not sufficient to make a person fluent. Having an interpreter accompany the Deaf child all day and to lunch and social activities is not considered full inclusion. The Deaf child should be able to communicate directly with ALL individuals in an education setting. The legislation draft should specify that Deaf students be exempted due to their unique language and allowed to be considered for special education placement. A provision should be made to the draft that the LRE definition for Deaf children is different than for their hearing counterparts with disabilities and requires special consideration. Thank you for your time reading this.

200. While inclusion may be beneficial to children with disabilities, I do not agree that deaf children should be included in this type of program. It doesn’t fit their needs. I’m deaf myself and value the importance of sign language for deaf children. Sign language is very important for a deaf child’s communication and learning through education. In other words, deaf children should be allowed to have access to deaf schools. If there is no deaf school available, a “mainstream” program is best to allow them to attend normal classes in a normal school setting with interpreters provided. They have those two choices that are best for them. I grew up mainstream and never have been in a disability classroom. I’m just as normal as other hearing people; I just have a lack of hearing. My mother refused to allow me to be in such disability classroom because she knows I do not need to be in there; she’s absolutely correct. So, please do not allow deaf children to be part of this inclusion program. It’s not what they need. Thank you for listening.

201. I am not Deaf but I have more than 32 years of experience in the field of deaf education. I have taught in Schools for the Deaf and in the Mainstream (a prior attempt to categorize children with vast
     differences and attempt to make a one-size-fits-all educational system).
     High quality early childhood programs must take into consideration the individual needs of each child to maximize academic and social development. Unfortunately, the lack of a true understanding of the
     needs of most Deaf and hearing-impaired children has led those forming the regulations to focus on speech and hearing as being the answer – it is not. Instead, providing an easily accessible, language-rich
     environment where all participants can communicate, learn, grow and develop is a what every child needs. I am speaking of an accessible environment where students with similar differences (hearing
     losses) can interact and communicate freely with each other and the adults in their environment using a rich, visually accessible language (American Sign Language) to develop a strong linguistic foundation.
     Of course inclusion is the ultimate goal! Teachers who have the skills and knowledge of American Sign Language can pass that language onto their students in a natural manner. In turn, those students will interact with each other. They will grow – linguistically, academically and socially. It is then, with a solid language base, an understanding of their own differences, pride in being Deaf and an awareness of how to navigate the hearing world that they will have a chance at true inclusion.

202. I am in support of creating individual needs of deaf and hard of hearing children D/HH through continuum of education placement. Early language acquisition is important and inclusion alone is not the best solution and is best left towards to appropriate educators who have conducted extensive research and they are Deaf schools across the US who employs similar process in providing continuum of education for D/HH children. The issuance of more policy restrictions by people who are not familiar with the long history of D/HH education will further harm D/HH children.
     Many other countries have adopted Convention on the Rights of People with Disabilities as mentioned in Jeff Rosen’s comment. It is important that we recognize and support deaf and hard of hearing children’s education and language acquisition be delivered in the most appropriate way, which is through early childhood intervention/programs.
     Article 24 Section 3(c.) of the Convention on the Rights of People with Disabilities:
     “Ensuring that the education of persons, and in particular children, who are blind, deaf or deafblind, is delivered in the most appropriate languages and modes and means of communication for the individual, and in environments which maximize academic and social development.”

203. My 3 year old son has a mild hearing loss and minor pronunciation issues that have qualified him for placement in a wonderful school for kids with hearing loss. We love that he spends all day in a small setting with a highly trained and experienced teacher of the deaf. His vocabulary, which was already above average, has exploded and his speech is more clear in just three months. Our goal is that by providing specialized services now , he’ll be fully mainstreamed later. We were not sure if he would qualify and we did look at other preschool. Prices in our Ohio city started at 12k a year and went to 17k. I do not think that siphoning that much money away from our public school system is sustainable – plus I’m sure that the school district would still be providing his assessments, therapy, etc.
     seems it would be much more efficient to work on making sure that our existing specialized settings are also high quality preschools, rather than trying to diffuse services to dozens of different schools.

204. For Deaf children, “inclusion” is not the answer. In fact, it is the MOST restrictive environment. Deaf kids need to be socialized and educated in an accessible language community. That cannot be achieved where one child is isolated and receives limited communication through an interpreter. The least restrictive environment for Deaf kids is with other Deaf Kids where ASL is the language of instruction. Don’t deprive Deaf children of the basic human right to communication access. Inclusion isolates Deaf children.

205. Comments of
     American Society for Deaf Children
     California Association of the Deaf
     California Coalition of Agencies Serving the Deaf and Hard of Hearing
     California State University Deaf Education Program
     Conference of Educational Administrators of Schools and Programs for the Deaf
     National Association of the Deaf
     on
     U.S. Department of Health and Human Services
     U.S. Department of Education
     Policy Statement on
     Inclusion of Children with Disabilities in Early Childhood Programs

     The American Society for Deaf Children, California Association of the Deaf,
     California Coalition of Agencies Serving the Deaf and Hard of Hearing,
     California State University Deaf Education Program, Conference of Educational Administrators of Schools and Programs for the Deaf, and National Association of the Deaf hereby comment on the above referenced document.

     We have reviewed the document and relevant law, policy, and research. Although the development of this policy statement may be well-intended, we believe it should not be disseminated in its current form. The policy statement is not necessary, and it does not balance the legal provisions that apply to placement. It takes a one-sided view that assumes that all children should be placed in a general education setting without considering whether that setting can meet the child’s needs. We recommend that the Departments change the focus of this document from advocating for physical inclusion in general education settings to ensuring that all children receive the services, supports, and settings they need, including specialized settings.

     At the outset, we note that the premise of this document is false. There is no legal basis for an “inclusion” policy statement. The word “inclusion” as used to promote a particular placement for a child is not found anywhere in the Individuals with Disabilities Education Act (IDEA) statute or regulations, the Americans with Disabilities Act (ADA) statute or regulations, or Section 504 of the Rehabilitation Act (Section 504) statute or regulations. Promoting “inclusion” based on these laws is misguided. None of these laws require it.

     A basic principle of the document with which we can agree is that children with disabilities should not be excluded from schools and public and private early childhood programs. Federal law – Section 504 and Titles II and III of the ADA – prohibit such exclusion. However, ADA and 504 do not require all students with disabilities to be placed in general education settings, nor do they prohibit early intervention or early childhood services from being provided in specialized settings. This policy statement mixes up ADA and 504 obligations with the Least Restrictive Environment (LRE) provisions of IDEA. They are not one and the same.

     IDEA mandates that placement decisions be based on a child’s individual needs – after those needs have been determined by a thorough evaluation by qualified evaluators, goals for the child have been established, and the services needed to help the child meet those goals have been described. Placement may be in the general education setting or in a specialized setting. As the Department has stated:

     Placement decisions regarding a preschool child with a disability who is served under Part B of the IDEA must be individually determined based on the child’s abilities and needs as described in the child’s IEP. 34 CFR §300.116(b)(2). State educational agencies and LEAs should engage in ongoing short- and long-term planning to ensure that a full continuum of placements is available for preschool children with disabilities. To achieve this goal, a variety of strategies, including staffing configurations, community collaboration models, and professional development activities that promote expanded preschool options are available. (U.S. Department of Education, Dear Colleague Letter, February 29, 2012)

     Under IDEA’s Prior Written Notice (PWN) provisions “parents of children with disabilities must be informed that the public agency is required to have a full continuum of placement options, as well as about the placement options that were actually considered and the reasons why those options were rejected.” (Assistance to States for the Education of Children with Disabilities and Preschool Grants for Children with Disabilities, Analysis of Comments and Changes, 76 Fed. Reg. 46588)

     The Department has issued further guidance applicable specifically to deaf and hard of hearing children. It has made clear that “[a]ny setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of [a free appropriate public education] and cannot be considered the LRE for the child. Just as the IDEA requires placement in the regular educational setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” (U.S. Department of Education, Letter to Bosso, August 23, 2010, Letter to Stern, September 30, 2011, also see Deaf Students Education Services; Policy Guidance, October 26, 1992, 57 Fed. Reg. 49274)

     The Department has stated:

     The LRE requirements . . . express a strong preference, not a mandate, for educating children with disabilities in regular classes alongside their peers without disabilities . . .
     With respect to the recommendation that the placement for children who are deaf or hard of hearing be based on the child’s communication needs, [the IEP section] . . . clarifies that the IEP Team, in developing the IEP for a child who is deaf or hard of hearing, must consider the child’s language and communication needs, opportunities for direct communication with peers and professional personnel in the child’s language and communication mode, and the child’s academic level and full range of needs, including opportunities for direct instruction in the child’s language and communication mode.

     With respect to strengthening the continuum of alternative placement requirements, nothing in the LRE requirements would prevent an IEP Team from making a determination that placement in the local school is not appropriate for a particular child. [The continuum of alternative placements section] already requires each public agency to ensure that a continuum of alternative placements is available to meet the needs of children with disabilities for special education and related services . . .
     The process for determining the educational placement for children with low-incidence disabilities (including children who are deaf, hard of hearing, or deaf-blind) is the same process used for determining the educational placement for all children with disabilities. That is, each child’s educational placement must be determined on an individual case-by-case basis depending on each child’s unique educational needs and circumstances, rather than by the child’s category of disability, and must be based on the child’s IEP. We believe the LRE provisions are sufficient to ensure that public agencies provide low-incidence children with disabilities access to appropriate educational programming and services in the educational setting appropriate to meet the needs of the child in the LRE.
     . . . [W]e agree [that Congress made clear its] intent that State funding mechanisms support the LRE requirements and do not provide an incentive or disincentive for certain placement decisions . . .
     (Assistance to States for the Education of Children with Disabilities and Preschool Grants for Children with Disabilities, Analysis of Comments and Changes, 71 Fed. Reg. 46585-46586)

     Likewise, the Department has issued interpretation and policy letters clarifying that infants and toddlers and their families may receive services outside settings deemed the “natural environment.”

     “ . . . § 303.344(d)(1) requires that the identification of the early intervention service needed, as well as the appropriate setting for providing each service to an infant or toddler with a disability, be individualized decisions made by the IFSP Team based on that child’s unique needs, family routines, and developmental outcomes . . .” (Early Intervention Program for Infants and Toddlers with Disabilities, Analysis of Comments and Changes 76 Fed. Reg. 60158)

     Further:
     The legislation amends current law to recognize that there may be instances when a child’s individualized family service plan cannot be implemented satisfactorily in the natural environment. The Conferees intend that in these instances, the child’s parents and the other members of the individualized family service plan team will together make this determination and then identify the most appropriate setting in which early intervention services can be provided. H.R. Conf. Rep. No. 108-779, at 238. (U.S. Department of Education, Letter to Morris, June 7, 2005)

     This is in keeping with best practices recommendations from professionals. For example, the Joint Committee of American Speech-Language-Hearing Association (ASHA) and the Council on Education of the Deaf (CED) recommends:

     When determining the setting for services for families and their young children:

     • consider home, community, and program settings (including center-based programs) that provide full support for language and communication development for the child and family

     • base recommendations on a comprehensive assessment of the child and the family’s priorities, resources, and concerns

     • provide families with comprehensive information about all programs and providers

     • encourage families to visit all programs providing services to young children with hearing loss and their families

     • support families in selecting the programs, providers, settings, and services that best meet the needs of the child and family

     • recommend programs and services that employ qualified providers who are fluent users of the language(s) and communication modality (or modalities) of the child.

     (Joint Committee of ASHA and the Council on Education of the Deaf, Natural Environments for Infants and Toddlers Who Are Deaf or Hard of Hearing and Their Families, not dated, http://www.asha.org/aud/Natural-Environments-for-Infants-and-Toddlers/, emphasis in original).

     The Departments of Education and Health and Human Services policy statement confuses LRE with placement in the general education setting. In fact an LRE for one child may be different than an LRE for another. This document treats all infants, toddlers, and young children served under IDEA as though they all have the same needs, which can all be met the same way. It ignores the individualized character of early intervention and early childhood education. The document stresses the provisions of the law that encourage placement in general education settings without adequately balancing them with clear law and policy that stresses consideration of individual needs.

     Further, IDEA requires States to ensure that their funding mechanisms do not create barriers to properly placing the child. (20 U.S.C. 1412(a)(5)), 34 C.F.R § 300.114) Suggestions in this document that only general education settings should be funded (p. 12) conflict with the law and should be removed. Recommendations that States should use resources to push “inclusion” only (p. 7) conflict with law and best practice. Recommendations that Individualized Family Service Plan (IFSP) Teams and Individualized Education Program (IEP) Teams develop “goals, progress measurement, strategies, and supports” that can only be implemented in one setting (p. 12) conflict with law and best practice. Recommendations that parents should be encouraged to advocate for “inclusion” (p. 12), rather than appropriate settings and services, conflict with IEP development and PWN provisions. In addition, they are deeply hurtful and insulting to parents who search high and low for a program that can truly meet their child’s needs.

     The document cites research to show the benefits of “inclusion.” However, the research used to justify the position statement is not inclusive of all students with disabilities. Typically studies on this topic do not include children who are deaf or hard of hearing. Deaf and hard of children constitute a small percentage of IDEA-served children. The count of IDEA-served deaf and hard of hearing children is around one percent of the age 3-5 IDEA population and one percent of the Part C population. (Out of 745,349 IDEA-served children age 3-5, 9,325 are documented in the “hearing impairment” category (U.S. Department of Education, IDEA Section 618 Data Products: State Level Data Files, http://www2.ed.gov/programs/osepidea/618-data/state-level-data-files/index.html#part-b). Out of the 339,071 infants and toddlers served under Part C (ECTA Center, Part C National Program Data, http://ectacenter.org/partc/partcdata.asp), fewer than 3500 are documented as being deaf or hard of hearing (Centers for Disease Control and Prevention, Summary of 2013 National CDC EHDI Data, http://www.cdc.gov/ncbddd/hearingloss/ehdi-data2013.html). Therefore, it is not likely that deaf and hard of children appear in research samples. A comprehensive research review that did look at the experience of deaf and hard of hearing children came to a different conclusion: children who are deaf or hard of hearing face great difficulties with communications and interactions with hearing peers in “inclusive” settings (Yu-Han Xie, Y., Potměšil, M., and Peters, B., Children Who Are Deaf or Hard of Hearing in Inclusive Educational Settings: A Literature Review on Interactions With Peers. J. Deaf Stud. Deaf Educ. (2014) 19 (4): 423-437, doi:10.1093/deafed/enu017.

     To the extent that this document states that general education settings should be required to accept and serve children with disabilities under Section 504 and the ADA, with appropriate accommodations and auxiliary aids and services, we heartily agree. We are pleased that the Department of Education and Department of Justice have been issuing guidance on the obligations these laws confer on public and private entities, as applicable, for the past several years. The document at hand should build on the work that has been done in this arena and provide assistance to entities in carrying out these obligations. For example, in November 2014 the Department of Justice and Department of Education issued joint guidance on the obligations of public schools to provide “effective communication” to individuals who are deaf or hard of hearing (and others). This thorough guidance spells out the ADA requirements that public schools must ensure that communication with deaf and hard of hearing individuals is “as effective as communication with students without disabilities.” Schools must provide “auxiliary aids and services” to provide “effective communication.” In determining appropriate auxiliary aids and services the public school must give “primary consideration” to the request of the deaf or hard of hearing individual (or parent). (U.S. Department of Education, Frequently Asked Questions on Effective Communication for Students with Hearing, Vision, or Speech Disabilities, http://www2.ed.gov/about/offices/list/ocr/docs/dcl-faqs-effective-communication-201411.pdf)

     These requirements apply to the public programs identified in this document. (Private programs also have ADA obligations.) If a preschool is truly going to be “inclusive” for deaf and hard of hearing children it must ensure that such effective communication is provided. Inclusive environments for deaf and hard of hearing children include:

     • professionals who are fluent in American Sign Language (ASL) and the methods and approaches used to support deaf and hard of hearing children’s ASL acquisition

     • professionals who are fluent in spoken English and the methods and approaches used to support deaf and hard of hearing children’s spoken language acquisition

     • professionals who are trained to support visual technologies such as communication through video over the Internet and flashing notification systems

     • professionals who are trained to support listening technologies such as hearing aids and cochlear implants

     • deaf and hard of hearing professionals who can serve as role models to children and can provide real life information to families, most of whom are hearing

     • a critical mass of age-level and language peers.

     (Adapted from National Association of State Directors of Special Education (NASDSE), Deaf and Hard of Hearing Students Educational Service Guidelines, not dated)

     Finally, any statement that a Federal agency produces should be devoid of inflammatory language. The word “segregate” and its variants historically have been used to describe the egregious practice of oppressing African-American individuals in all areas of society. These terms have no place in discussions about specialized settings for vulnerable populations. Similarly, describing “inclusion” as a “moral imperative” is deeply offensive to the parents who seek out specialized settings in order to afford their children full linguistic and communicative access to professionals and peers.

     In closing, we recommend that the Departments shift the focus of the document to ensuring that all children receive the services, supports, and settings they need and ensuring that entities receive the informational and financial resources necessary to help deaf and hard of hearing children reach their full linguistic, social-emotional, and academic potential. We stand ready to assist the Departments in this endeavor.

     Contact:
     Barbara Raimondo, Esq.
     Conference of Educational Administrators of Schools and Programs for the Deaf
     baraimondo@me.com
     301/792-2884

206. I am more concerned for Deaf children who will be affected by this policy. When we talk about least restrictive environment, we need to remember that access to language is of paramount importance. It is especially important in Deaf children’s language development. If we compare two different situations: a deaf child in a group of hearing children versus to a a deaf child in a group of other deaf children. Just to think of the access to discourses, or lack thereof, should be taken into consideration when we attempt to define what counts as inclusion and what does not. Inclusion is not the answer for Deaf children, or for any other children who need different avenues to access to information than one would expect in tradition classrooms.

207. As a Deaf person and as a former student of both mainstreaming and school for the Deaf, I didn’t feel totally included until I attended at school for the Deaf, where I evolved and built self-confidence. I urge you to maintain a flexible variety of placements; not all deaf children benefit from one single educational placement.

208. Being Deaf, I object to the proposal. The proposal means poor quality of education thus the government will end out giving out financial entitlements
     This proposal may work for children with disabilities but not Deaf, Deaf Blind Hard of Hearing . Our children have a disability of communication.,
     LRE means meeting each child’s unique communication needs.
     Again I oppose the proposal

209. Being Deaf, I object to the the proposal as it will result in poor quality of education for many Deaf; Deaf Blind; and Hard of Hearing thus the government will end up giving out financial entitlements. That proposal may work for children with disabilities but not for our children whose disability is communication, LRE allows the child to have a program that meets unique communication needs.
     Again, I oppose the proposal.

210. The definition of LRE is misinterpreted by many. It must be clearly defined, when your child is in an environment where all SPEAK IN SAME LANGUAGE should be considered as part of LRE. Deaf people use American Sign Language, and placing them in an environment where all teachers, staff and students use American Sign Language SHOULD be appropriately defined as part of LRE. Right now, all over the America, the Educators are doing the opposite by placing Deaf child with all other hearing children. The Deaf child is alone and suffering. Is that LRE? Same thing, I feel history repeats itself with this proposal, the “INCLUSION” policy. I totally oppose this proposal. I can see it can work for other disabilites but not for Deaf children.

211. I am a hard of hearing adult and I have to say I do not agree with this proposal. As it does not include those that are Deaf or Hard of Hearing. I myself grew up in a small inclusive deaf classroom as a child in the state of IL. Then moved to KY during my 6th grade year where I was thrust into special education with no interpeters or any understanding of what was going on. Upon my 7th grade year I atteneded Kentucky School for the Deaf. Wow, was my whole world opened up. Prior to my attendance I had no social skills, no knowledge of the enviroment, no communication skills. No skills to be a part of my enviroment. KSD taught me these skills and I have become a person who is able to be a part of the community and enviroment. My educational skills has also improved. I had no knowledge of science, very low math skills, social studies, and other academic skills. I learned these different academic tools during my attendance at KSD. The students who are placed in the wrong enviroment should not have to suffer for it is not morally or conceptually fair to a child to put them in the wrong place even if the Government thinks that they are in the right do they personally know each child themselves to make that decision for them? I think not! Please think about these children that are misplaced and give them a chance to find knowledge in what choices there are out there for them. Provide them with the proper paths, pushing this proposal prevents that!!

212. Bottom line is one size does not fit all.
     Every deaf has its own needs at different levels. Simplicity is the best policy for all deaf children.

213. I agree with the following comments that Jeff Rosen, Lisa Purnell Noll, Paul Levenson, and Steve Longo said. Inclusive does not work well for all disabilities. Please put the Deaf into consideration before passing this because it will cause a major problem. I am Deaf and so is my son. We come from a family 4 Deaf generations so there are more Deaf people in our family. Deaf people have different needs than the disability you are trying to help. Thanks!

214. I do NOT support this policy statement. It is too much of a blanket statement saying that children will thrive if they are placed in an inclusion setting. There are tons of research out there that show inclusion do NOT work. My own mother is an example of how inclusion failed; she did not attain the necessary English language skills until she was 11 years old when she finally enrolled at Kansas School for the Deaf. There, she was among Deaf peers and she thrived with sign language. Because of her experiences, she has always made sure that I was in a signing educational environment. I have grown up in Deaf schools all of my life, and would NOT trade it for one second for anything else. My Deaf daughter is now 21 months old and has been in an early childhood program at California School for the Deaf in Fremont since she was 18 months old. How she has learned language is amazing; she now knows over 200 signs and I am able to know what she wants to eat, if she is feeling happy, if she wants to read a book or play with her blocks, and I clearly understand what she is telling me about her dolls. This has been done through American Sign Language (ASL). I fully support the idea of early intervention programs, but I do NOT support the idea of inclusion. This is not a one-size-fits-all thing you can just throw at in the field of Special Education. Every child is unique; is that not why we have IDEA in the first place? Again, I do not support this policy statement.

215. As a Deaf woman who has provided advocacy and counseling services for Deaf children and their schools/ families for the past 20 years, I can’t tell you how so many Deaf children I have met who are language deprived to various degrees due to the misconception by parents/ schools that placing them at the home district without sign language or without peers who can sign would be better of them. And, woe, how I saw the impact on their emotional and psychological well-beings. I can relate to them due to my own experience growing up where my own parents also made that mistake as they were told that it would be in my best interests to to place me in a school without sign language so I could learn how to “survive” in a hearing world. To their shock, I suffered greatly emotionally, socially, and fell behind in school grades, and they quickly placed me in a different program where I would be around peers who could sign. It took me years to recover from that experience.

     Please be aware that many states, such as California and Kansas, already has unique resources to provide appropriate placements for Deaf children to help them thrive to their fullest potential. These resources include Deaf schools or large mainstreamed programs that utilize the ASL-English Bilingualism approach in Education, which has been highly successfully for those who had access to language-rich settings early enough in their childhood (before Kindergarden if possible!). For Deaf children and their families, the focus on LRE should NOT be on Least Restrictive Environment but exclusively on Language Rich Environments!

216. Thank you for the policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. I support this policy and hope it will be officially released as soon as possible. The clear message in the policy statement about the benefits of inclusion and the resources provided in the appendices will help me as I advocate for my child. The recommendations for state and local education agencies will help change the system, so it is not as difficult for parents to find inclusive early childhood programs or as difficult for our children to be successful. An especially important recommendation is the inclusion of children with disabilities in proportion to their presence in the general population (natural proportions). The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond.

     My six-year-old son has Down syndrome and my first childcare experience for him was a wonderful inclusive place started by a family who had and understood children with special needs. Our family moved when my son turned 4 and it was impossible to find a similar place in our new location. The places we sent him to meant well but did not have the knowledge, understanding, or supports that would have enabled our son to be included fully in their programming. We finally alit on a private preschool in town dedicated by mission to inclusion and there realized how well it could serve our son as well as his typical classmates, which allowed us to advocate for his inclusion in a general education kindergarten classroom this year. Without that experience, I’m not sure we would have had the vision to push back against the recommendation for a more self-contained environment for our son. More such places need to exist! More such parents need to have that vision so that true inclusion can “trickle up” to elementary school and beyond. This policy is a step in the direction of making that happen.

217. Deaf children need to School for the deaf. That is best than hearing school. please.

218. Please send all deaf or hard of hearing children go to deaf school because very good education and social with other deaf people than hearing school. Please don’t leave deaf people feel too lonely in hearing school. Must go to Deaf school. Please.

219. The wording in the proposed draft fails to consider or acknowledge both immediate and long term consequences of institutionalizing language delay in L1 for the D/HH children. Applying this draft, or any other that neglects the role of language development in favor of emphasizing attaining uncertain communication skill sets, in practice would directly translate to placing them into ill-prepared public schools with insufficient training and resources. Nearly all of them in the U.S. currently lack the critical educational approach that utilizes a linguistically and/or culturally appropriate pedagogy when it comes to many D/HH children whose L1 is or has come to be American Sign Language (ignoring the approximately 20% who come from signing parents). By extension, some public schools would be, and have been, allocating those funding for other means or seek administrative strategies to reduce costs rather than fully promoting linguistically-appropriate and individual-specific language development for each D/HH child to maximize the full meaning and theory of inclusion in a relevant LRE educational setting.

220. That is a no-no for Deaf Education in the part of inclusion plan. No! I’m Deaf and I felt isolated when I was in the mainstreamed without the use of interpreters or with the use of interpreters. The interpreters was not qualified and the teachers and I did not have peers to communicate with. I joined Deaf School later and I was given an opportunity to be very involved in student body government at HS and extra curriculum activities because I was able to communicate with other peers who are Deaf in sign language. We share same common – ASL. Deaf education is no part of special Education. Separation.

     No No. I oppose. Please take my word very seriously. Deaf Education- no in part of the inclusion plan.

221. I am an early childhood educator with a master’s in early childhood unified (which encompasses both children with special needs and those who are typically developing.) I have 3 years of experience working as an early childhood special education classroom. The programs I worked in were state funded, district schools with “inclusive” programming. The majority of the children in my classroom had an identified disability and an IEP. Less the half of the children were peer models (typically developing children) for the children with disabilities. In many ways this is an excellent model. The children with disabilities are still having their needs me through me and other specialists. They also have typically developing children who can model appropriate behaviors, interactions and guide their learning. It is no secret to an educator that a child will generally respond better to playing a game with his or her peer than one-on-one rote instruction. The program is even excellent for the typically developing students. My student’s who were typically developing were generally in my classroom for a period of 2 school years. I saw a huge amount of growth in their patience, their ability to understand and empathize with others who were different from them. It is a wonderful opportunity for growth for these students. Beyond that – they were given a high quality preschool education. Their pre-kindergarten academics did not suffer with the inclusion of their peers with disabilities. I must applaud the Obama Administration’s efforts to increase the availability and quality of preschool education for all children. However, before we look at massive changes to existing preschool education programs I think that other issues need to be addressed. I live in the state of Kansas and right now there is a serious lack of funding for education in my state. Our schools and children are suffering. In my own classroom I did not have enough help to support the children in the way they needed to be supported. I had 2 para educators working beside me, but their pay was abysmal and the job extremely challenging and it was difficult to keep the help that I and the children so desperately needed. The people who work in early childhood education and special education must be better compensated for the work they are doing. The other issue that must be accounted for is the severity of a child’s needs. I am all for inclusion and I must applaud the Obama Administration’s efforts on this issue, however last year I had nine 3-year-old children in one of my classes with special needs. 4 of these children were non-verbal and low-functioning. 2 of these 4 were also aggressive toward their peers. These 4 children needed constant one-on-one support. On top of the 9 children with special needs there were 5 children who were typically developing. One of these 5 children was developmentally delayed and 2 of the 5 children had severe behavioral problems. There were not enough adults to support the level of need in the classroom. This was my last year working in an early childhood special education classroom. Unless significant changes are made to the current system there were be more talented teachers and para eduators who walk away. I am no longer willing to jeopardize my health and my own family for this job. (Working 60-80 hours a week is no longer an option!) I won’t get into it but there is the major concern that outside of school district programs children with special needs do not have any additional support. All early childhood programs for children in my area are only about 3 hours a day. Many of these children spend most of their day in non-district child care facilities where there is a lack of support. I love teaching young children, it is my passion, but there are many changes that need to happen in the world of early childhood education.

222. Be sure that all parents of Deaf and Hard of Hearing students get ALL information of choices in using language (ie. ASL, speech). I graduated from Deaf School way years ago as many of school timers got great self esteem with excellent education. Since laws made for all other disabilities which is not fit for Deaf and HoH due to visual language while other is able due to language by phonics. I could see how much damage to Deaf and HoH students due to many medical people give parents wrong information or left out the important information (ASL-other choice method of using sign language). I believe that most Deaf and HoH students suffer in public school – lack of quality interpreters. Please to see the law not include Deaf and HoH – making sure that students have their abilities of using. Early in learning by ASL/sign language help quickly learn . Please listen Deaf/HoH professions -researchers ..
     Thank you

223. Please consider the unique needs of deaf and hard of hearing students .. I have seen too often that “full inclusion” for deaf and hard of hearing students equals student thrown into mainstream settings where students report never feeling that they fit in. And then I have known of deaf and hard of hearing students who do feel they fit in.. Not all deaf h/h students do well with out other deaf peers to learn, socialize, and grow with. As a deaf or h/h person it could be difficult to find and connect with a role model who doesn’t share your language nor world experience. I hope these statements help convince you that a continuum of placement options for deaf and hard of hearing students is imperative to serve well the diverse needs of this community.

224. I have taught inclusive preschool classes for 10 years. As inclusive classrooms, we are the Least Restrictive Environment for Early Intervention in PreK for 3-5 year olds. We serve all children with special needs …those with physical or cognitive disabilities or impairments, those with developmental delays, those on the Autism Spectrum, and others…along with an equal number of children who are typically developing.
     Inclusion benefits all children involved…all people involved. We all learn from each other. In 2011, I graduated from UCF with my Master’s in ExEd with a focus in Early Childhood Special Education. The interactions with my students’ remind me how to teach them…to be consistent and clear…to be fair and fun…how to be big…and when and how and why to be small.
     I know that regardless of disability all children have the ability to play and learn…and I’m awed by their process.
     Simplifying explanations helps children form a foundation of understanding …then elaborating with more expressive words… expands their vocabulary and piques their interest…they like big words…these strategies help all students. I taught a four year old boy who seldom spoke at home…and even then was not understood…and he didn’t speak at school for 2½ months. His first…and very dramatic words at school…as he held high a piece of toast…“Ms Sue… ’totes’…delicious!”
     The idea that all children on the autism spectrum do not want social contact is not altogether true. The intense anxiety they feel in social situations is created by not knowing how to relate to others. They need to be taught the social communication skills directly which others learn through observation, and the inclusive early intervention classroom offers many opportunities for practice. Though children do learn from adult actions, children are wired to imitate and learn from their peers…in our inclusive classrooms the appropriate behaviors students learn from each other benefit us all…and they all must learn what we call… appropriate alternative behaviors for those other behaviors we prefer they not mimic.
     Inappropriate behaviors by anyone should not be allowed to continue…regardless of ability. Appropriate alternative behaviors need to be taught to replace the inappropriate behaviors that a child has learned work…success teaches all of us what to do the next time we want something. We must teach them what will be successful in a classroom! Focus on ability…have high…though realistic…expectations of all children …challenge them…teach them to play… teach them to imagine…teach them to figure things out…teach them social skills…conflict resolution …and… letters and numbers…teach them how to learn…and hopefully to love learning.
     The key is early intervention…early support for maximum learning…now is when they can learn more…and with enthusiasm! …they learn through play. In preschool adults have the advantage of impressing children before they become distrustful by what they perceive as unfair treatment: they develop “resilience”
     They learn not just tolerance for each other…but the true value that each of us brings to our small community. They understand that we are all different…that we all have parts that aren’t quite done yet, and that it’s just fine because we all have parts that are really amazing, too!…they learn that we are all learning…and that hopefully we will always be learning.
     It takes a lot more than playing with students to get them ready for kindergarten. The interventions used for children with special needs greatly improve the lives of children who are typically developing, as well.
     Though some students truly do benefit from a separate environment and need that smaller class size and higher level of support to maximize their learning…many students make their greatest gains in an appropriately behaving inclusive classroom.
     Kids really aren’t that different from each other…or from adults…we all like to be given choices…to be asked…to be considered capable…to be appreciated for our efforts and acknowledged for the gifts we offer.
     We must include all children and introduce to the world our students-with-special-needs as kids first…everything else is incidental.

225. While inclusion in a general early childhood program may seem like a fantastic idea, it is not the best ultimate goal for every single child who has needs. I work with Deaf and hard of hearing people, so I will use this group as an example of what works and may not work for this group in terms of early childhood.

     1. Not every early childhood program and provider will be able to include all options for this group plus many other groups in th same building.

     2. There is not enough interpreters and Teachers of the Deaf for all early childhood programs and providers. A special education teacher does not have the same qualifications to serve as a Teacher of the Deaf.

     3. Not all states have districts spending money for children 0 – 3 years old. Some states rely on Medicaid to pay for support services, and not all support services needed by a Deaf or hard of hearing child can be covered by Medicaid.

     4. Some children get the most benefit if placed in a specialized early childhood program. The teachers in that progam are better equipped and skilled to work with this group. In a general early childhood program, the child may have support services for just a few hours a week, leaving the general teacher to do their best as they can the rest of the time.

     5. Deaf and hard of hearing children have a right to and deserve to interact with their Deaf and hard of hearing children on a regular basis, not just their hearing peers.

     6. Deaf and hard of hearing children have a right to and deserve to have specialized staff in the program full time. A general early childhood program will have a variety of skills and experience among the staff, so what one employee can do for one certain child may not be able to work with another certain child.

226. As we watch our children grow up, nothing like the proud thoughts of a parent watching the first wobbly steps, the emotional first day to school…and seeing language achievement in our children, specifically the Deaf children. Since the Deaf schools provide just this that we desperately ask not to take this lightly as studies show the benefits of “inclusion” generally do not include Deaf children.

     Studies that do look at Deaf children indicate that they experience great difficulties with communication with peers in general education settings. School districts are already struggling with budgets that leave Deaf children isolated in districts. Not to mention the vast majority of school districts not having staff members knowledgeable about educating, or communicating with Deaf children especially when districts cut essential services required for Deaf students out of necessity. The lack of direct access to the educational curriculum sets Deaf students aback from their hearing peers. Deaf children need to be assessed by qualified educational staff with experience and training in specific assessment tools and techniques required as mandated by law.

     The proof that our system and laws lack the assurance of Deaf education lives in the statistics, and feeds off the apathy and ignorance hid behind the status quo. Do not let this “inclusion” idea deceive you as it does many. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion. So I see how the policy statement on “inclusion” of children with disabilities in early intervention and early childhood programs disregards the individualized nature of the IDEA and assumes that the general education environment can appropriately serve all students. So you know I’ve SEEN firsthand that Deaf children with years of language delay as a result of being inappropriately inclusion-placed.

227. As the mother to four deaf children, and as a deaf person myself, I find it telling that almost every other deaf person who attended the mainstream program I did in the Chicago area has chosen to place his/her child in a deaf school setting.

     While I had decent academic and socialization opportunities while in a mainstreamed setting, I absolutely did not have full access to education, socialization, athletics, after school clubs, or anything of that kind. You wouldn’t have known it by looking at my long list of involvement in high school (everything from sports to Model United Nations to the award-winning school paper to the yearbook to Key Club), but I never experienced full access to everything. I was always involved, but never fully–and that was the gap that set me apart from others.

     Now that my children attend a deaf school, I am amazed at how they have far better language development than I did, and so much better access to academics, real-life experiences, and much more. I wish I had gone to a deaf school for all of my education, not just one year.

     Deaf schools must be included as part of the language on inclusion, especially when they offer such a wide range of services, language access (both signed and spoken), and a rich diversity in life experiences, academics, extracurricular activities, and everything else that create the ultimate learning experiences for any and all deaf or hard of hearing children. The bottom line is early language development is crucial to success–and deaf schools provide that without question.

228. As a Deaf person and educator of the Deaf, I urge you to change this draft. What superintendent James Tucker said is exactly what I am agreeing with. Inclusion is not the answer for Deaf children. Please reconsider

229. Early intervention is a guiding key on helping establish a language foundation whether it’s the English language or sign language. Which is why modes of communication (e.g. sign language, Cued Speech, auditory-verbal, Signing Exact English, Total Communication, SimCom, etc) whether combined or separately have seen varying successes when used with hearing aids, cochlear implants or none at all. Inclusion can succeed if given the proper support in a highly conducive environment. Inclusion can succeed if there are enough, for example, deaf and hard of hearing students. A larger ratio of deaf and hard of hearing students to hearing students would help with the social interaction aspect instead of feeling like the only deaf/hh student in class. But then again, many may not thrive in an inclusive environment. An individualized approach would be needed to gauge a child’s potential for success – educationally and socially.

     For me, I thrived in a regular school even though I was sometime the only hard of hearing kid (moderate to moderate-severe hearing loss) in the whole school only because I was able to benefit quite well with my hearing aid. I learned better by auditory-verbal means. And that was during the early 70s through high school into the early 80s. And through undergraduate and graduate colleges not needing interpreters or note takers. Today’s improved services, technologies and greater understanding on education will make inclusion a much more likelier successful prospect but that comes with a heavy caveat as always. The guiding mantra has always been “no one shoe size fits all.”

230. As a professor who teaches language acquisition and development of American Sign Language and English and as one who trains interpreters to work with deaf and hard of hearing children in K-12 educational settings I believe a policy of mandatory full inclusion would be be detrimental and devastating to health and welfare of deaf and hard of hearing children. A “least restrictive environment” for children can mean many things , but a fundamental aspect of a least restrictive environment is a community of language users that allows for enriched linguistic input that stimulates cognitive and neural development that promotes age appropriate language development. For some deaf and hard of hearing (D/HH) children an inclusive environment does provide an enriched language environment, but sadly this is not the case for many D/HH children. When D/HH are afforded a range of placement options, such as a specialized program that provides an ASL/English bilingual program, then those that are not successful in a mainstream environment have additional access to a placement option to get access to enriched language environment. Research has continually found that D/HH placed in an ASL/English bilingual environment are immersed in a rich language environment where they can explicitly and implicitly acquire language. The visual language environment for deaf children affords them full and unrestricted access to neural electrical input that stimulates language centers in the brain (Broca’s and Wernicke’s regions) . This promotes healthy cognitive and language development and research consistently shows that deaf children with native exposure to sign language from birth have language development that parallels that of hearing child with native proficiency.

     An additional challenge of placing D/HH solely in inclusive programs is that will greatly increase the dependence on sign language interpreters to provide communication access. Sign language interpreters provide “mediated” instruction for D/HH children between teachers and deaf children. A study done by Schick (2006) found that as many as 60% of the educational interpreters were not sufficiently qualified to provide sufficient communication access. Currently, states with the most stringent certification for sign language interpreters require that a sign language interpreter hold RID national certification or at least a 4.0 on the Educational Interpreter Proficiency Assessment (EIPA). 25% of interpreters who take the EIPA are able to get a 4.0 and a 4.0 rating means that the interpreter is able to provide access to 80% of the message. Unfortunately, while the EIPA of 4.0 is the currently the highest standard, less than 10 states require interpreters to have a 4.0 Some states require a 3.5 EIPA score, some require a 3.0, and some states, including DC have no standard at all, meaning that many D/HH who utilize sign language interpreters to provide communication access receive much less than 80% of language. A majority of Interpreter Training Programs prepare interpreters to work with adults and not children. Thus, a majority of interpreters who work in K-12 educational settings have very little training in basic child and adolescent development, little training on language and social development, pedagogy, curriculum and instruction, or how to work with children who are deaf and also have additional disabilities and challenges. Moreover, there is little on the IEP to ensure the quality of a sign language interpreter. Most IEP stipulate that a D/HH child have access to an interpreter, but there is no standard to assess the quality of the interpreter or to ensure that they educational staff and administration properly utilize and work with the sign language interpreter to ensure that the D/HH has robust communication access. In short, many interpreters who work in K-12 educational environment have limited training, there is limited understanding on the part of educational staff and administration on how work effectively with sign language interpreters, and many Interpreter training programs do not prepare interpreters to work in k-12 educational environments. It would be unrealistic to expect that deaf children would magically have their needs completely meet by many sign language interpreters, especially when there is limited means to ensure the reliability and quality of the communication they provide as they team with educational personnel.

     In summary, I believe that D/HH need a full range of educational options that include mainstream, inclusive environments, self-contained classrooms, and special school programs. D/HH have a fundamental need for a language community of users in which to acquire language, and also acquire cultural and social information to promote healthy self-identity and self-esteem. Providing D/HH children with a full range of options will allow this to be possible. Severely limiting this to only one placement option will leave many D/HH children all over the country isolated and in a language impoverished environment that will limit their linguistic, cognitive, social, and psychological well-being. Thank you for your consideration.

231. I was born to be DEAF from the 4th generation of DEAF/HOH. I was in early childhood school when I was two years old. I learned NOTHING! Until I was moved to Texas School for the DEAF in Austin from Mainstreamed school in Dallas around I was 12. I had learned so many things. I happened to be All-American Football player twice in High School and got involved with DEAF communities. Sign Language is my FIRST language. My family members are non and low educated which they have not socialize DEAFIES. They orally speak and hear not so well.
     The US Education Department has no right to push DEAFIES and HOH in early childhood schools. Their parents have a right to choose and make their decisions, not the government. Then How DARE the government spends BILLIONS dollars on Cochlear Implants as a robot as Ineffective!?!? The money has flied gone!!!! WE, DEAFIES and HOH, are like smothered by the stupid government. The government should retreat!!! We strongly recommend DEAFIES/HOH to be placed in DEAF schools………SO, back off or else!!!

232. I am writing as an Educator of the Deaf with 30 years experience, an Early Childhood Special Educator with 13 years experience, and as the mother of a young Deaf/ Hard of Hearing adult. Inclusion can be desirable for many young children with disabilities, however, it is not the least restrictive environment for most young Deaf or Hard of Hearing children and can impede their development of preacademic concepts as well as stifle their personal and social growth. Both professionally and personally I have seen the benefits of early accessible language for Deaf and Hard of Hearing children as well as the lasting devastating effects of impoverished language access during the early years. My experience as a teacher of the Deaf in the residential school setting, the public school setting, and at the post-secondary level, impressed upon me the critical need for D/HH students to have full access to a complete visual language starting from day one. While the educational settings I have worked in are vastly different, there is one thing that is common to all–those students who excell academically, socially, and vocationally are those who have a strong language base that was developed during the critical early years. For D/HH children this means taking advantage of the unencumbered visual channel for acquiring language. American Sign Language is the natural language fit for the visual channel. For those children with auditory access, spoken English can be provided in parallel with American Sign Language through the use of bilingual teaching strategies. Setting the stage for academic success begins early. Please re-think the wording of this policy statement so that young Deaf and Hard of Hearing children are not inadvertently penalized when their specialized needs can not be met in the general education setting.

     • From another mom of Deaf young adult, Deaf educator, and certified Sign Language Interpreter- I hope your remarks are heard. Well put and thank you

233. I strongly believe that there needs to be a continuum of educational placement options for students with disabilities. One child’s least restrictive environment is another child’s most restrictive environment. I have been working in a school for the deaf for 28 years and I’m insulted by the comment in the proposal that inclusion settings offer higher quality education than alternative programs. the teachers where I work have multiple degrees and the high school is certified by the NYS Board of Regents. The students have direct access to instruction because all staff members use American Sign Language and/or English depending on the need of the individual. Although I believe the authors of the policy have the best interest for children with disabilities at heart and want the best education possible, inclusion is not necessarily the best option.

234. I am the mother of an amazing Deaf daughter. She is an adult now, but when she was young we parents had to fight to keep her Deaf school open so it could continue providing a setting that is actually typical for children without a disability; one that provides natural language development in a setting that focuses on the important issue of learning. The language used in this proposed policy emphasizes ensuring infants and toddlers with disabilities receive services in natural environments or in settings that are typical for a same-aged infant or toddler without a disability. ASL is a natural language for Deaf adults, children and babies. Limiting their access by forcing them into an environment that frequently limits language development is counter intuitive and does the opposite of what you are proposing.
     Once again we are faced with a narrow idea of “best practice” when it comes to kids with different abilities. 20 years ago we fought to keep Deaf schools open for our kids to have a level playing field on which to grow. So very many Deaf kids have to fail in this “best” setting before they are allowed to blossom in the nurturing environment of actual “full inclusion” they experience at Deaf schools where their time is spent learning academics, art, sports and socializing rather than trying to figure out what is being communicated. We need to allow IDEA to work. If a mainstream setting works that is wonderful, but having a full continuum of options for children who are Deaf and Hard of Hearing has proven to be the best approach toward nurturing able, happy kids and growing them into able, happy adults.

235. As being Deaf myself and I also speak for the Deaf community anywhere in USA, I strongly agree with James Tucker’s comments about the draft, “The Policy Guidance draft must include provisions for Deaf and Hard of Hearing infants and toddlers to ensure that they achieve language benchmarks in American Sign Language and English. Thousands of Deaf and Hard of Hearing children become language-delayed as a result of “inclusive settings” where they are unable to fully access language models”. What is more? It is a big mistake to make this policy without getting input from the Deaf communities as well as from the DEAF Heads of various schools for the Deaf. Thank you for listening.

236. As a teacher of the Deaf and Hard-of-Hearing, I do not support this. I can confidently say that there is not one right method for instructing ALL deaf students. Children learn differently, have different needs, and have different backgrounds. Some children will find that a School for the Deaf will be their LRE, and some will find that an inclusive setting will be the best fit. The government should NOT make this decision for all students. As IDEA purports, each family has the right to make the decision for their child. There are various factors that affect where the LRE is for a child, and those include, but are not limited to family upbringing, language exposure, communication mode/language in the home, socioeconomic status, personality, etc. The U.S. Department of Education cannot control these factors; therefore, it should not control the educational placement for all children.

237. It doesn’t apply to Deaf and Hard of Hearing children. I have seen maaaaany DHH students have lack of language acquistition without exposure of American Sign Language and have low self-esteem than those students who have acquired language through American Sign Language and they have more self-confidence. Please support continuum of Deaf Education and communication needs for Deaf and Hard of Hearing students.

238. Deaf and hard of hearing children need to be exempted from this full inclusion legal movement early childhood initiative. Their education needs to be in an environment where they have full communication access to instructional information. Developmentally, young children learn through play and horizontal interaction and with non signing peers (hearing), Deaf and Hard of Hearing children will be impoverished of critical linguistic and social growth. Check out Evidence-Based Best Practices in Deaf Education by Marc Marschark!

239. I never ask you to help. I just like for you to respect my ASL (America Sign Language) and Deaf culture. I am not here to be fixed. I’m here to give an answer to fix your attitude . Please don’t make ANY new law (s) about Deaf babies to young adult. Please listen to the Deaf community, and please allow the Deaf community to make their own LAWS, such as ASL, etc.

240. Deafness is a low incidence disability and students who are Deaf tend to use American Sign Language. Inclusion may not be the best fit for Deaf students because American Sign Language models are rare in public schools, so for those students, residential schools for the Deaf would be the best fit for them.

     In 2015, many Deaf students suffer from language delay because they are not getting what they need in public schools, some of them ended up referred to residential schools for the Deaf when they are of high school age.

     That is why inclusion may not be the best fit for those Deaf students, they should be referred to residential schools for the Deaf to ensure that they have access to language, whether it is American Sign Language or spoken English (with cochlear implants but with regular check ups with audiologist and speech pathologist),

241. As a parent of a newly diagnosed hoh daughter whom is 9 weeks old I am fearful of her to be in an inclusive program. Inclusive programs and educational programs are a not one fit all for everyone. It should be up to the guardian or parent along with sound advice and evidence of the therapy team to find the best fit for the child not the best fit one program for all.

242. This new bill, if passed, could have a devastating effect on the lives of so many especially for the Deaf and hard of hearing children. The term “least restrictive environment” may mean the public mainstream for many children with a variety of disabilities, but not for D/HOH children, especially very young ones. Even those who are exceptionally bright, are identified early and have had all the right resources put in place, often describe their mainstream experiences to be challenging at best and at times, terribly isolating and difficult. D/HOH children are not just children with “broken ears”. They require specialized instruction from teachers who are trained to work with them. They need D/HOH peers and role models in order to develop positive self-identity and pride. As it is now, children are often placed in their public schools, without adequate support and flounder until they are lucky enough to be placed in a specialized program. Often, they have developed overwhelming delays and low self-esteem. Imagine being placed in a situation where you are surrounded by teachers, curriculum, typically hearing peers and social life that is not accessible to you! This policy is “penny wise and pound foolish” for so many reasons! Please do not allow this bill to pass in some misguided ideas of “inclusion

243. I don’t think you understand the need for the Deaf and Hard of Hearing children. Why? All other disabilities are hearing people which is why it is easy for hearing policy makers to favor them more than us. I don’t believe whoever proposed this policy actually know us very well.

     I wonder if any of you went to Gallaudet University to get their feedback on this?

     I grew up in North Carolina. I went to Central NC School for the Deaf in Greensboro and NC School for the Deaf in Morganton. I did very well in school and I didn’t want to go to public school why? They will not be able to grant me the magic of Deaf culture and the friendships with my people. I am from hearing family and they did everything to make sure that I got my fair share between deaf and hearing worlds. They decided ASL was proper sign language and I believe it helped me to achieve my goals in my life.

     My goals?

     I graduated from Gallaudet University with BA in Government (Political Science).

     I interned for Senator Kay R. Hagan (D-NC) during summer of 2011.

     I am going back to school for Master in Public Administration.

     I am part of Delta Sigma Phi Fraternity includes both deaf and hearing brothers across the country and I still support Deaf schools.

     I am concerned about the future for deaf children with unintended consequences from the policy of policy makers in which they didn’t consider or understand them.

     Please take your time to visit Gallaudet University in Washington, DC and ask everyone about your policy statement.

     Timothy P.

244. As a deaf individual that did not receive any intervention until I was three years old, I am encouraging further clarification or modification to ensure deaf and hard of hearing children are given special considerations under this policy. My parents were based overseas when I was discovered to be deaf. Thus they were not given a full spectrum of choices that are commonly available to deaf and h-o-h children. This led to frustrations for everyone involved in my family as I was growing up.

     My parents sincerely regret the limitations of information thinking it was the best choice. Now you declare in this policy that this would be ‘full inclusion’ but to me it’s a repeat of what my parents went through.

     Every deaf and h-o-h child are different and each one should be looked at individually. Each parent should be given all the information so they can make an informed choice. Most of the time a deaf school would be considered a full inclusion environment than putting the child in a fully hearing environment with no comparative peers.

     Please read all the comments specific about deaf and h-o-h above carefully and ensure they are heard.

     Thank you.

245. Young children with disabilities must be seen as individuals, with IFSP’s and IEP’s determining services and identifying unique needs. To determine through a blanket policy, that “inclusion” is the answer, denies a continuum of services. It denies the deaf student the option that may be the best, language rich environment in which they will thrive. Deaf Schools are not the placement for every Deaf/HoH child BUT they should not be rendered obsolete by policy. Inclusion has allowed many students with disabilities an opportunity to come into the light and be educated in their neighborhood schools with their peers. Deaf children and their parents should be afford the same right, to be educated with their peers, in deaf schools, with full access to language.

246. To whom it may concern:

     I would like to first thank you for drafting this policy. After careful review of the draft, I can appreciate the spirit and idea behind “inclusion.” However, I respectfully disagree with that approach for several reasons.

     As the draft identified under the subheading “challenges to inclusion in early childhood programs, the first challenge is “attitudes and beliefs.” This is the most difficult challenge we must overcome to serve the best interest of individuals with disabilities.

     Attitudes and Beliefs: The most highly reported barrier to early childhood inclusion that has remained largely unchanged over the past several decades are attitudes and beliefs related to inclusion and children
     with disabilities. False beliefs and negative attitudes about inclusion may be influenced by misinformation of the feasibility of inclusion, fear of the unfamiliar, resistance to changing existing practices, stereotyping of children with disabilities, the worry that children with disabilities will divert attention and resources from their peers without disabilities, and lack of awareness of the benefits for all children, including those without disabilities and those with the most significant disabilities. Any effort to expand early childhood inclusion must be accompanied by a strong focus on shifting attitudes and beliefs.

     Let us examine our attitudes about the ADA, IDEA, Section 504 of the Rehabilitation Law and other legal guides http://www.ada.gov/cguide.htm#anchor65310. I think when we fail to recognize that our attitudes could be the reason to create, yet another law, we will continue to miss our mark – to provide the best education for all children with disabilities and other children.

     The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities.

     Ignorance of this is a testament of our attitude to chose to ignore what is already there and to reinvent the wheel. Why?

     IDEA Interpretation and Perceived Barriers: Some jurisdictions misinterpret IDEA’s natural environment policy as only allowing early intervention services to be provided in children’s homes, and not in inclusive early childhood programs. Other jurisdictions misinterpret IDEA’s LRE requirement as only allowing preschool special education services to be delivered in preschool programs operated in a public school building as opposed to non-public school settings, such as child care and Head Start where services can be delivered. A mixed delivery system of public and private high-quality early childhood programs is important to increasing the availability of inclusive opportunities for children with disabilities.

     IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. Perhaps more accountability is needed to enforce IDEA provisions instead of a new law.

     Ignorance of this is a testament of our attitude to chose to ignore what is already there and to reinvent the wheel. Why?

     Lack of Staffing, Training, and Expertise of the Early Childhood Workforce: There is a large amount of variability in the training, education, and expertise of the early childhood workforce. Providers may lack basic knowledge and competencies in child development, early childhood pedagogy, individualizing instruction, managing challenging behavior, promoting social-emotional development, and scaffolding learning across activities and between peers. This affects all children, including those with disabilities, and may present a challenge to providing a high-quality inclusive early learning experiences.

     Let’s examine attitudinal barriers with hiring practice of qualified and sometimes overqualified and expert individuals with disabilities who are often turned away from positions. Let’s look at the number of individuals with disabilities with college degrees who are unemployed and ask ourselves why we say lack of staffing. Could it be that our attitudes prevent us from seeing them as qualified to be ROLE MODELS for children with disabilities?

     Ignorance of this is a testament of our attitude to chose to ignore what is already there and to reinvent the wheel. Why?

     Lack of Comprehensive Services: The lack of comprehensive services delivered in early childhood programs is also a barrier to inclusion. Programs like Head Start and Early Head Start provide children with a coordinated set of comprehensive services. Outside of Head Start, however, few scaled programs offer the same type of coordinated comprehensive services. The multiple systems that provide services to young children, such as the early care and education, early intervention, and special education, and health including pediatric medical homestand mental health, often deliver services in separate settings. The lack of delivery of comprehensive supports in early childhood programs may be a barrier to the full
     participation and success of children with disabilities in inclusive settings. Children with disabilities, more than other children, may have increased interface across several systems, and may, therefore, be disproportionately affected by the lack of comprehensive services offered in any one system.

     Current programs are comprehensive. Current attitudes ignore this, ignore qualified individuals with disabilities who can effectively and successfully execute these programs, and serve as a beacon of hope for children with disabilities. These attitudes are barriers that must be addressed with accountability measures, not another law.

     Limited Time and Commitment to Build Partnerships: A key ingredient to successful inclusion is a strong partnership between general early childhood, early intervention, special education, and related services
     providers who provide services and supports. Many communities believe in the importance of inclusion but have made little progress due to limited time or a lack of commitment and support from leaders. Fostering
     relationships between providers require an on-going commitment. Equally important is a commitment across providers to build strong partnerships with families, children’s first and most important advocates.

     The notion of limited time and commitment to building partnerships is a serious attitudinal barrier. Numerous successful individuals with disabilities, allies, organizations, and constituents may not have access to partnerships. This speaks to the attitude that some hold that they know what’s best for individuals with disabilities – make decisions without listening to those impacted.

     I am in opposition to the “one size fit all, inclusive approach” because, as a Black Deaf male, I know what it means to be left out in that environment. I know what it feels like to be sent to a special school because at first they (those that wanted to include me) thought I was mentally ill only to find out I was hard of hearing – two years later.

     I suggest we review current laws, ADA, IDEA and others and build accountability parameters within them. Finally, I suggest we examine employment practices for barriers that could be preventing qualified individuals with disabilities, role models who are beacons of hope for children with disabilities.

     After all, seeing someone like yourself who has made it, is the inspiration to a fulfilling life.

247. Thank you for this opportunity to comment.

     As a parent to a young child with a cognitive disability I have already, unfortunately, encountered an education environment in which it is almost as if my child has to demonstrate that she is ‘worthy of’ or ‘skilled enough for’ inclusion, rather than it being up to the environment to be accessible in ways that make inclusion possible for her. I am heartened by the proposed statement and it gives me hope that I will not have to fight as hard for something that really is a right for my child – rather than something that can be granted one moment and then taken away the next – to belong with her peers and community.

248. Not all deaf children benefit from a policy designed to be inclusive. An inclusive policy, while well-intentioned, very often is in practice exclusive. Being in proximity with hearing children is not a guarantee of access to the education or early intervention that deaf children are entitled to. Let’s leave open the options for deaf children to have a range of placement options available to them.

249. On the surface, this bill “looks” wonderful, and I can see the value and where it will benefit many children who do not currently have access to inclusion. However, I cannot get past the LRE mandate of IDEA. Assuming that an inclusive setting is meeting the IDEA requirement of LRE is dangerous ground. For many children with disabilities, the LRE may actually be a state school program of sorts, or an isolated setting within a mainstream school. Attempting to put all differently abled children in a box and wrapping it up in a neat package is a mistake. For example, many individuals have already commented on Deaf and Hard-of-hearing challenges where inclusion may do more harm than good. Rather than mandate inclusion, why not hold educational facilities of the parent’s choice to higher standards? It is my belief that D/HH children need to be in educational settings with similar peers and with instructors that are capable of direct communication with them. Inclusion in such a situation is not always ideal.
     Another concern with this bill is the labeling of differently abled children. Will we ever get past the need to call them “disabled” when the truth is they are just abled differently than the norm? “Dis” refers to an inability to learn, which does not apply to many children under this umbrella. These children just learn differently and process differently. On account of that, putting some of them in the mainstream setting with accommodations does not benefit them on account of barriers to information processing due to teachers unexperienced and unqualified to meet their needs.
     Instead of this bill, what we need to have in place is a bill protecting parent rights to decide their child’s educational plan. Inclusion needs to be one of many options offered to parents, not the “be all end all” to the dilemma of supporting differently abled children in the educational setting.
     I oppose this bill as written and would strongly encourage all policy makers to instead think of the ramifications of passing such a bill. The key to success is not in forcing all children to be included in a mainstream setting, but in empowering parents and professionals to evaluate children as individuals and place them accordingly with open access to whatever is decided upon.

250. It is very important that the needs of Deaf and Hard of Hearing children who use American Sign Language (ASL) be considered. Inclusion in the closest “home school” is often the most restrictive environment for young Deaf and HoH children. For these students, a language environment where adults and peers are using ASL as the language of instruction and social interaction would be the least restrictive environment. If the language needs of the student are not met, then the FAPE requirement is not met.

251. I am a Deaf female and want to share a bit about my educational background. I am grateful that I experienced a variety of educational settings, such as attending an oral school for the deaf, being mainstreamed at two elementary and jr. high schools, attending a Deaf high school on the Gallaudet campus, being mainstreamed nearby at an all boys Catholic school and spending a year at Deaf & Hard of Hearing school in Germany while an exchange student. The educational setting that I LOVED the most was attending the residential school for the Deaf while spending my afternoons taking classes nearby at Gonazaga College Prep, an all boys school. I believe that hearing people who created the the draft about inclusion had good intentions in wanting children with disabilities feel included. However, I would like them to think about that while “inclusion” might be great for many but it should not be the only option. Inclusion is not the answer for ALL deaf people as there are some who have not done well in the public school system. There should be a continuum of educational settings made available for all children with disabilities for each child should be recognized as individuals with specific needs.

252. save our deaf school these deaf children need big role model deaf not hearing thank u

253. Parents, Colleagues and Allies:
     The U.S. Department of Education and Department of Health and Human Services have drafted a policy statement on “inclusion” of children with disabilities in early intervention and early childhood programs. The Department of Education has posted a blog about the document and is seeking feedback from stakeholders http://www.ed.gov/…/including-young-children-with-disabili…/. Please take a moment to respond!
     There are serious flaws and deficiencies in this document. To summarize, it disregards the individualized nature of the Individuals with Disabilities Education Act (IDEA) and assumes that the general education environment can appropriately serve all students. CEASD strongly encourages you to submit comments to the blog. Every school for the deaf has a book full of stories of children who came to school with years of language delay as a result of being inappropriately placed. We need to tell these stories again and again. In addition, we have developed talking points you can use in your response if you wish:
     • “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.
     • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.

     • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.
     • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.
     • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.
     • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.
     Barbara Raimondo
     Government Relations Liaison
     Conference of Educational Administrators of Schools and Programs for the Deaf

254. I can’t speak what works best for any of the other disabilities. But I can surely say through the expereince of my own life, school, college and my job. That I never felt included at the family table growing up nor at any public school and its event. The real “INCLUSION” occured in a Deaf school and Deaf settings. In other words being with my people. Thats what fits me.
     A continuum of educational choices should remain as an option for every parent and child. Educational placement should be a choice.
     Won’t this so called “new drafted Inclusion policy” mean getting all these different assortments of specialist into every educational building across the states?

255. LRE is not always what you may think and often for Deaf children the closest or “home School” is not the LRE. The meaning of inclusion is different for everyone and this law will only hurt deaf and hard of hearing children. Education is not a one size fits alll.

256. I am deaf, and I grew up in mainstreamed schools and it taught me a lot of things, not only school subjects such as math, science, english, etc but to socialize with those “hearing people” as well. It is very important because we live in “hearing world”. If deaf children are forced to be in deaf intuition, they may miss that out and once they are in the “real world”, they would be lost and umcomfortable. As a teacher student of early childhood education, no I do not think it is necessary to force them in all disability intuition unless its parents’ choice to put their child there.

257. I disagree this policy, because government don’t see anything special for almost 200 years of deaf education is not that great, because hearing teachers are not using ASL so therefore itself is our first language so English is always in the classroom and ASL is socialize communication as well as Chinese talk Chinese Language, English People talk English language, and Deaf Sign as ASL as our language. Let me tell you my experience in education as I am hard of hearing ! I went my first class at Stanford School (Garden Grove School District) Garden Grove, CA. I learn nothing in first 6 years and My parent want me go to California School for the Deaf. It is my parent choice then District turn it down because they want me to be dumb all the way !! My parent fought in the court for two years so finally I enter at CSD Riverside as learned a lot and so happy so why they so control me !! I don’t like it !! Let the parent and children pick what they want !! Thank you

258. Despite the thoughtful and articulate nature of the proposed policy statement, as well as its appropriateness for many disabled children, it must be stated that the guidelines and assumptions about inclusion do not reflect a forward thinking approach to Deaf and hard of hearing children.

     As a faculty member in a Deaf Education teacher training program, and as someone who has extensive experience working with programs for Deaf and hard of hearing children, the issues of language deprivation, lack of peers and the overwhelmingly ill-equipped resources and personnel that characterize mainstream/general education programs create sustained challenges and long term deficits for Deaf and hard of children on social, emotional and academic levels. It is critical that we have an established policy that offers a continuum of appropriate placements, as mandated by IDEA, including special classes and special schools.

     It is too often the case that we assume that a general education classroom is the appropriate placement for all children. However, for Deaf children, their opportunities to develop early language abilities, to foster rich cognitive growth and social connections, and to become effective and productive citizens requires that their environments be accessible. This document incorrectly assumes that general education settings are the most appropriate for Deaf and hard of hearing children. However, if a setting has no opportunities for a Deaf or hard of hearing child to learn directly from adults or peers, if Deaf and hard of children are prevented from learning American Sign Language, if they are in environments where approaches to learning English are counter-productive and historically ineffective, it cannot be considered the least restrictive environment. Provisions must be included to identify special schools as an appropriate and viable option for Deaf and hard of children.

259. This document fails to meet the mark. I would urge you to go back to the drawing boards. Inclusion is only one of a spectrum of options that must be maintained for children with disabilities and especially children who are deaf and hard of hearing.

     Your position paper places inappropriate emphasis on inclusion as a model of choice and as representing a least restrictive environment for all children with disabilities. For the majority of deaf and hard of hearing children inclusion is the most restrictive environment where they will struggle to gain access to peers and their teachers and other professionals who are charged with educating these children. Because of their unique communication and language needs deaf and hard of hearing children are seriously restricted by an inclusion environment. Interpreters are not a solution to access. Deaf children need placement in environments where they have a significant, critical mass of peers who share their communication and language system, American Sign Language and professionals who are specially trained to work with them and provide education, counseling, and all aspects of education using American Sign Language and English.

     For deaf children IDEA calls for a spectrum of options which should include Schools for the Deaf, Center Schools, Resource classrooms and full inclusion. The individual needs of the child for social, linguistic and full educational access is the primary requirement of IDEA. Your document fails to recognize this.

     To summmarize some of the deficiencies in your Draft Policy statement I quote from the Council on Educational Administrators of Schools for the Deaf (CEASD).

     • “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriately evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

     • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.
     • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that the children experience great difficulties with communication with peers in general education settings.

     • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

     • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

260. As a Deaf individual, a Deaf education teacher and parent of a Deaf child, I strongly urge the committee to include education at a School for the Deaf to the continuum. For many Deaf and Hard of Hearing children this placement IS all inclusive, where instruction is directly taught with no language barriers. Many “inclusive” public school programs for the Deaf are not the least restrictive environment for Deaf children.

261. I strongly support & agree with James Tucker that we should value and keep our Deaf Education system. No changes in Inclusion at all. Leave it as is.

262. Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

     All various special need children and Deaf/ Hard of hearing children have different way to learn educations.

263. Inclusion of children who are deaf and hard-of-hearing (DHH) is not always the best option. There is no one single “Least Restrictive Environment” (LRE) for DHH kids. They deserve to be offered a continuum of placements, including academic and extracurricular scenarios in which they have full, direct language access.

264. As a former educator and a counselor trained in working with children and adults with disabilities I am thrilled to have the opportunity to read and comment on this draft. As an educator for parents and an advocate for children and adults with hearing loss, I have many concerns however. Inclusion is an incredibly important concept and program for children with disabilities, with one exception- children who are deaf or hard of hearing (D/HH). Often times, inclusion into a “regular” education setting or mainstream environment is EXCLUSION for a D/HH child. When children cannot communicate with their peers, teachers, aides, and/or therapists this quickly becomes an environment that, for most other children, should be conducive to learning but instead becomes anxiety provoking and restrictive. Because of the myriad of communication options and placements/settings for D/HH children, this “one-size-fits-all” model of inclusion just does not fit for this category of disability. Hearing loss is only a disability due to the limitation of ACCESS to langauge and information and forcing all D/HH children to be “included” with their peers into programs proposed does not provide access. Please reconsider this proposal as applying to ALL children with disabilities and begin a conversation about the differences for D/HH children and how to appropriately identify programs that will truly be inclusive for them. The goal is for all children to be able to learn and achieve their fullest potential- that can only be achieved for D/HH children when they are offered full access to all of the language in every setting for their interventions and educational programming.

265. As a preschool teacher of students with special needs in an urban area, I have a wide range of children with disabilities. I strongly believe preschool is one of the most unique opportunities to fully include all children with special needs. Preschool is a time to explore. Allowing children to learn from their peers is key during this stage. Even my lowest students (who are unable to walk or talk and have significant cognitive impairments) have made strides from watching and interacting with their peers. Typically developing children also benefit from the interaction. It teaches children we are all the same. However, what makes me most upset with current practice is that children with slight delays or speech problems are placed in self-contained classroom. I feel this is a disservice to these children. These children will thrive and make enormous gains in Gen Ed classrooms. Creating team teaching classrooms or push in services is the key to success of preschool aged students. It will also help prepare these children for kindergarten and prevent the over classification of preschool children entering kindergarten.

266. We are in opposition on a new policy for special education students and full inclusion.
     There should not be a policy on inclusion. Policies should reflect what is best for EACH student individually in the least restrictive or natural environment. All policies should support current law and not a specific philosophy.
     My disabled son greatly benefitted from special needs placement in a small, tightly-focused program geared toward the needs of children with cerebral palsy. It was properly positioned with highly-trained staff, all facility modifications, and a compassionate and caring attitude towards fulfilling not only the physical and educational needs of my child, but the emotional and nurturing side that all children need.
     When we went to look at schools, the child study team in our home district showed us in-district placement options, but their training in special education, as well as my knowledge of my child’s needs, led us all to agree that out-of-district placement in a specialty school was the APPROPRIATE placement to meet his needs. You cannot dictate a one-size-fits-all system and expect it to work. The last thing in the world I wanted was my son to be strapped into a wheelchair and stuck in the back of a classroom while the teachers tried to juggle the many-faceted needs of an active and eager classroom of students.
     My husband and I found an amazingly high quality program in which my son thrived and blossomed. The decision for placement should be left to parents working in tandem with the home district’s educational professionals who know the range of specialty services available in the area.
     I am writing to ask you to please appropriately implement the current laws in place, and not set new policies that contradict the current laws for least restrictive or natural environment.

267. I’d like to point out certain language in the 1992 OSEP Deaf Students Education Services Policy Guidance Report, as well as in a Federal statute and its accompanying regulation (specifically, 20 USC Sec. 1414(d)(3)(B)(iv) and 34 CFR 300.324(a)(2)(iv)), that directly refute the Draft Policy Statement’s presumption of inclusion insofar as it pertains to deaf and hard of hearing (DHH) students.

     The 1992 OSEP Policy Guidance Report straightforwardly rejects any presumption that DHH students should be sent to regular or local school districts prior to individualized consideration. As that Report points out, “[a]ny setting, including a regular classroom, that prevents a [DHH student] from receiving an appropriate education that meets his or her needs including communication needs is not the LRE for that child.” That Report also expresses concern that the LRE provisions of the IDEA and Section 504 are being “interpreted incorrectly to require the placement of [DHH students] in programs that may not meet the individual student’s educational needs.” Regarding the supposed primacy of regular school districts, the Report notes that “some public agencies have misapplied the LRE provision by presuming that placements in or closer to the regular classroom are required for [DHH students], without taking into consideration the range of communication and related needs that must be addressed in order to provide appropriate services.”

     This language cannot be squared with the blanket presumption of inclusion the Draft Policy Statement is proposing, particularly as it applies to DHH students.

     As for the Federal statute and regulation, both expressly require that the DHH student’s IEP team consider certain “special factors” in making its placement decision. Those factors are “the child’s language and communication needs, opportunities for direct communications with peers and professional personnel in the child’s language and communication mode, academic level, and full range of needs, including opportunities for direct instruction in the child’s language and communication mode.”

     Those special factors make clear as a matter of law that individualized placement is paramount for DHH students. Any blanket policy of inclusion, therefore, must yield to it. And for good reason: decades of research and experience have shown that the least restrictive environment for DHH students is determined not by presumptions, but by substance — that is, which environment best serves the student’s social, educational, and language needs.

     In short, the federal government itself has repeatedly acknowledged — as a matter of policy and of law — that a blanket presumption of inclusion is not the correct approach as it pertains to DHH students. Instead, it must be one of individualized consideration and placement. The Draft Policy Statement should be revised to correctly reflect that.

268. I am very concerned and dismayed with the proposed policy statement, a statement that is in direct conflict with IDEA. As long as we continue to argue for a one size fits all approach we will continue to harm children. Decisions regarding what is an “inclusive environment” and the best placement for a child should NOT be determined by a blanket policy statement but rather by assessing the needs of the child and putting the CHILD FIRST when making the decision. What is inclusive for one student may not be inclusive for another, and this is often the case for deaf and hard of hearing students when they are placed in environments that are not linguistically accessible. The opportunity for full linguistic and cognitive development should be the most important consideration in determining appropriate placement and services.

     Below I restate key points included in CEASD’s response to the Department in opposition of this proposed policy statement:

     “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriate evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

     IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.

     The U.S. Department of Education has issued policy on many occasions stating “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Research shows that deaf and hard of hearing children who do best are those who are identified early and receive appropriate early intervention from specialized providers. These providers typically are not found in general early childhood programs.

     Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

269. Fine ur video but no one teach us English enough to participate in written English I expect hearties will control this methods of participation damn !

270. As a Deaf individual who has experience in a public school as a student and in a residential school for the deaf as a teacher and as an administrator, there are several glaring concerns in regards to your joint policy statement.

     While inclusion may be the ultimate goal for students with disabilities, this will not work with deaf and hard-of-hearing students for a multitude of reasons. For one, deafness is a low incidence disability that is unknown to many professionals, and the needs related to deafness often go beyond the ability and capacity of a regular classroom setting.

     Secondly, deaf and hard-of-hearing individuals whose primary mode of communication is other than spoken English will not receive access to instruction in their primary language, thus forcing them to deal with the largest barrier they will deal with the remainder of their lives: communication. To remove deaf and hard-of-hearing students from alternative settings and forcing them into inclusion will cause them to lose a sense of belonging to a community and a sense of pride and self-confidence.

     Additionally, the joint policy statement views inclusion as a “one size fits all,” which will pull deaf and hard-of-hearing students from their least restrictive environment, as well as a language rich environment. This is a violation of each student’s Individualized Education Plan (IEP), which is a federal document. It is also a violation of the Individuals with Disabilities Education Act (IDEA), as these students would not be provided with a Free Appropriate Public Education (FAPE).

     It is my recommendation that the joint policy be reviewed and updated with the inclusion of individuals with disabilities who are leaders in education, including deaf leaders.

     Gregory A. Mendenhall
     High School and Transition Principal
     Ohio School for the Deaf

271. I grew up in a school for the deaf, and by all means I felt inclusive. My English teacher could sign. My PE teacher can sign. My academic advisor could communicate in my native sign language. I signed to my classmates who signed back to me. I took speech classes, even, which I flunked big time. I asked my family who can hear- do you understand my speech? They said “Big NO, Paul. We understand your sign language much better. If Dept of Ed thought putting me in a mainstreamed school, I would flunk that school big time. We need our government to recognize different languages, communication venues and language culture can vary and some specialized schools can deliver better. Blind schools, Deaf schools, that sort should be in continuum and be a choice instead of a forced entry.

272. If the US DOE really wants to “proudly celebrate” the ADA and the IDEA, then let’s reflect on what the true meaning of IDEA is and what we have learned from the past 40 years. We cannot legislate or mandate by policy or define “inclusion” any more than we can define “least restrictive environment” for all children. To do so is to deny IDEA’s fundamental and indispensable right to “Individualize” based on every child’s unique strengths and needs. Physical inclusion can never ensure that all children have their specialized needs met. Deaf children, by example, must have meaningful access to language and communication. Proximity to non-disabled peers alone does not guarantee their inclusion in an environment that fosters high expectations and intentionally promotes participation in all learning and social activities and fosters their cognitive, communication, physical, behavioral, and social emotional development. If the DOE wants to celebrate IDEA, celebrate the continuum of alternative placements that includes special schools and programs as critical for meaningful inclusion. Help build a culture that recognizes that no single placement of setting or inclusive environment that meets the needs of one child–automatically meets the needs of another. We know the DOE knows that one size does not fit all. Early Childhood is monumentally critical to the development of deaf children. IDEA has already recognized that the deaf child’s inclusion in a high quality learning environment must meet their unique language and communication needs, must have specialized and
     highly qualified staff–must have access to age appropriate peers and role models with whom they can communicate and must meet the total child’s needs. Lets draft a policy statement about early childhood education that recognizes this. A policy statement such as the one you have brought forward that states that “that high quality early childhood programs cannot occur in separate or specialized settings”, does a profound injustice to children who are deaf.

273. It is almost guaranteed that a full inclusion for disabilities will take away their unique needs and rights. Each disability have their own specific needs especially how they learn. Not all disabilities learn the same way. Being Deaf myself, I have benefited so much from classes of my own peers. We nourish each other through out my education years. Being placed in inclusion class environment, that will be completely taken away from me. I am not in favor of this bill and movement.

274. full inclusion may work for some children but not all. I am a seasoned professional educator and do not think that a child that is Deaf or severely HOH can get the specialized language and communication instruction they need without being in a setting where teachers understand language development for Deaf children and are providing language daily so that it benefits the child. You could put a hearing English speaking child that had developed language competencies in English in a class where only German was spoken and in time the English speaking child would learn German because he can HEAR it being spoken and has a native language to help him attach meaning to it. A Deaf child must develop language before he can learn more than basic things. And we all know that most language development takes place before a child enters school.

275. I am commenting today as a Deaf adult and as a teacher of the Deaf (16 years). I grew up using ASL and attended a school for the Deaf. I have taught Deaf students of all ages, from K to 12 and at a variety of settings (mainstreamed, school for the Deaf, special program). I cannot stress enough that there is a severe lack of understanding about how to educate our Deaf children.

     The premise that the LRE for a Deaf child equals inclusion with hearing students is something that has been perpetuated for quite some time now and it is harming our Deaf children. The only true LRE is when Deaf students interact with peers and are able to communicate freely, ask questions freely, and participate freely in not only school, but also in extracurricular activities.

     Bilingual education, where American Sign Language is used to teach all subjects, including English, has been shown over and over again to be the only true approach that provides total access to a language and learning. Students raised with the bilingual approach routinely outperform their mainstreamed peers in every subject, including reading and writing (in English).

     Implementing a law or the idea that full inclusion for ALL disabled students is dangerous and does not address the real issue with Deaf education.

276. It is no question that early intervention as a general concept is the key strategy to map out for a child’s educational attainment in his/her upcoming academic years, from K through higher education. However, steps involved leading to the achievement of that goal all depend upon each individual child’s personal, cultural, and language background. My life testimony: As a profoundly deaf person growing up in a hearing family using spoken/written English, I went to all three main types of schools between K and 12: Oral (listening and speaking), mainstreamed, and center (residential). Now a professor of a large, elite university, I am thankful for acquiring ASL that enabled me to thrive my positive learning experience with no language barrier – the key is DIRECT communication between student and teacher (deaf or non-deaf alike). Based on my life experience, I would become an ashamed citizen if our society through DOE allow us to slip backward instead of moving forward towards the approach of providing full continuum of educational placement, as well as full equal access to education. Wake up, America!

277. I am conning by US dept of edu and US dept of healthcare s policy changing. I strongly agree with James Edward Tucker and keep the policy as old for children rights!

278. Without intentionally wanting to make this a long response, I am seeking further clarification here with the definition. The Departments define inclusion in early childhood programs as including children with disabilities in early childhood programs, together with their peers without disabilities, holding high expectations and intentionally promoting participation in all learning and social activities, facilitated by individualized accommodations, and using evidence-based services and supports to foster their cognitive, communication, physical, behavioral, and social-emotional development; friendships with peers; and sense of belonging.

     Is this to also say if a deaf child is placed in an early childhood program with other hearing children, it will be everyone in that room that uses ASL as opposed to speaking? That would be full inclusion as doing otherwise would not be and allow me to explain why.

     I would imagine that research would easily show that a child at the age of of 0 to 5 is not going to really be able to fully understand an interpreter at that age as they are still developing their language skills. They need to learn the language first before they can rely on an interpreter.

     The deaf children, for the most part are not going to be able to hear what is said, so therefore the only way that the deaf child can be fully included is that everyone in that classroom uses ASL as a hearing child likely would learn ASL far easier than a deaf child would learn the spoken language at the ages of birth to age 5. So if this policy is saying that every classroom that has a deaf child will have everyone using ASL, if it is that child’s primary mode of communication, then I would have no problem with this policy.

     But logic also tells me that is not the case here, although there’s not enough clarification in the policy, and I’d imagine this policy would state that each deaf child that is included in a classroom that consist of mostly hearing people, would not only fall behind, but also the costs of that would likely skyrocket due to the costs of interpreting, in addition to what would make the shortage of qualified interpreters and even bigger crisis.

     While I realize that there are various communication options when it comes to deaf children, it is the parent that should be able to decide on a particular communication option, and not that the government that decides it for them which is exactly why this great country was founded. It is the parent that should make the choice for the child as they are with them more than anyone else and they should not have to live with a “one size fits all” solution. Trying to implement a “one size fits all” solution will not only make these policy makers shoot themselves in the foot, but it will also lead to more children falling behind. Instead of allowing the children to fall behind, policies should be set to accommodate each and every child’s needs, whether the parent decides to implement the listening and speaking concept; cued speech; ASL, SEE and whatever else is out there.

     With that said, unless this policy supports full actual inclusion at 100% by having every single person in the classroom use ASL for deaf children, whose primary language is ASL, I do not support this policy.

279. I am in opposition to The U.S. Department of Education and the Department of Health and Human Services draft policy statement regarding inclusion of children with disabilities in early intervention and early childhood programs for the reasons as articulated by James Tucker and Jeffrey S. Bravin. As a professor in the English Department at Gallaudet University for the past 23 years, it is my professional opinion that one setting for the education of deaf or hard-of-hearing students does not fit all. Language acquisition and English development should be in parallel balance with ASL acquisition and d/Deaf/HOH culture for a rich life. The deaf/Deaf population will not be served well by this policy as currently written.

280. On behalf of the IDEA Infant and Toddler Coordinators Association (ITCA), I want to take this opportunity to enthusiastically support this draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood programs. The policy will provide greatly needed support at the state and community level for those who work every day to increase and enhance the availability of quality inclusive opportunities for young children with disabilities starting at birth. We appreciate both the Departments’ of Health and Human Services and Education openness to input and believe having the statement issued jointly by both agencies will increase the likelihood of its successful implementation. We congratulate the Departments for their work on this important topic! Thank you!

281. Every professional study ever done finds that including children with intellectual disabilities in classroom with their typical peers produces positive results for both groups. I have seen this first hand with my 8th grade daughter with Down Syndrome who has been included since kindergarten. It has been a huge academic and developmental benefit to her and we have several stories of how her presence has also specifically been a positive influence on others. This policy is not optional – it is a must have for us as a society to move past segregation and into accepting and including those with intellectual and other disabilities.

282. Outstanding job by all the Departments and agencies for this joint policy statement that is a concise outline of the standard of service we all want to see applied in real life. The policy provides a concise yet detailed overview that includes both the literature and legal foundations support for inclusion and linking it to that IDEA requires individual decisions and the healthcare systems and supports. Thank you! The list you provided of all the resources to help families, administrators, higher education faculty and direct service providers provide high quality inclusive services is invaluable. And it expands the policies developed in the 1970’s and 80’s regarding mainstreaming. As you point out in your initial statement, these recommendations are not new and yet in 40 years have not been implemented. I hope as you move this policy and process further, you also address fully the fiscal and political reasons why progress has not been made in this essential endeavor. They are the major barriers to full inclusion and the primary one is funding. It is wonderful to put forth our best ideals and desired outcomes for all children and families but if sufficient and consistent funding for all that this document recommends are not in place and stable before implementation is mandated, then we are no further than we are today. Demanding that LEA’s and state governments do all that is expected and needed on already overburdened and diminishing budgets, personnel shortages and a congress that can’t seem to agree on any measure of future progress for our country, sets the stage for continued disappointments, inadequate and unqualified services across environments and more failed expectations. I fully support your immense efforts and ambitions but please consider all the ramifications of putting forth this policy with no sustainable monetary policy as its companion. I’ve been working in this field for over 40 years and still believe we can do what is best for all and hope I see it come to reality in my lifetime. Thank you for the opportunity to respond.

     • A well informed definition of the “Least Restrictive Environment” for Deaf students is required before policy can be made that will impact learning opportunities for our students. A careful examination of the level of ‘expertise’ that policy makers possess on this topic is critical to developing an equitable and accessible statement on inclusion for children who are Deaf. Can we be assured the highest standard possible has been applied for those who are making policy that will affect Deaf students? Do they have the level of expertise needed to make a statement on what inclusion looks like for Deaf children? Is their an understanding of what rich, engaging, and effective learning opportunities look like for Deaf learners? My request is that we carefully consider these points as this statement is developed. Thank you for the opportunity to share my comments and concerns.

     • The First Five Years Fund (FFYF) commends the Department of Education and Department of Health and Human Services for focusing greater attention on the importance of expanding inclusion of children with disabilities in early childhood programs. High quality early learning opportunities significantly benefit all learners, including children with disabilities, and we appreciate your commitment to promoting greater access to well-designed and well-implemented early learning programs. As you finalize this important new guidance, we urge you to consider the following recommendations.

       State Systems and Coordination: FFYF supports the draft guidance’s focus on a range of potential state level policy improvements, including establishing an inclusive early learning vision, promoting multi-agency coordination, establishing robust data systems, and promoting accountability. Local leadership, including close coordination among public and private community providers is essential to meeting families’ early childhood needs, but we believe strong statewide systems are necessary to promote quality and expand program access, especially for students with disabilities.

       FFYF agrees that State Advisory Councils should play a central role in ensuring that states not only create an inclusive early learning culture, but also proactively align policy and funding to support community efforts to serve students with disabilities and their families. Finally, we support the guidance’s recognition that accountability systems and incentive structures should be in place to promote inclusion and overall program quality. Given local educational agencies’ growing role in early learning delivery, we urge you to use the guidance to encourage states to embed developmentally appropriate early learning indicators in their Elementary and Secondary Education Act required accountability systems.

       School Leaders, Educators and Staff Capacity Building: FFYF agrees with the draft guidance’s recognition that the lack of staffing, training and expertise within the early childhood workforce is an obstacle to greater inclusion of special education students in early childhood programs. High quality early childhood programs require well-trained school leaders, educators and staff, and we support your recommendation that states provide cross sector professional development and technical assistance. Greater national, state and local efforts are needed to develop an early learning work force with competencies in child development, early childhood pedagogy and other skills required for teaching the nation’s youngest learners. Achieving this vision will require improved educator preparation and professional development, including ensuring that existing federal resources provided for these purposes include a focus on early learning. The draft guidance appropriately calls on states to leverage existing early learning programs to better serve students with disabilities, but the final guidance should also specifically urge states and districts to use existing preparation and professional development funding provided by the Elementary and Secondary Education Act and the Higher Education Act to build an educator workforce with greater early learning competencies.

       Family and Community Engagement: FFYF welcomes the guidance’s call for local educational agencies to build strong connections with families, including equipping school leaders, educators and other staff to work collaboratively with parents and guardians. Increasing family and community understanding of the benefits of including students with disabilities in high quality programs must be a greater priority for district leaders. This step includes using local educational agencies as a parent resource, even in instances when the district does not provide early learning services. Schools are powerful anchors in our communities and serve as natural connection points for families to learn about the benefits of early childhood education and care and local opportunities to access high-functioning programs.

       Relatedly, districts should be called on to build strong connections to community providers and develop plans for using district resources to promote inclusion and improve quality so that all children, including children with disabilities are well-served. For example, the guidance should specifically address available options for using Elementary and Secondary Education Act resources, as some districts already do, to support high-quality early learning, home visiting and other early learning initiatives.

       Thank you for carefully considering these suggestions for strengthening this valuable and timely guidance. We appreciate the Departments’ collective effort to build public understanding of the value of including students with disabilities in early learning and for providing a roadmap for strengthening state and district policy in this area.

     • While the goal is to integrate all people into the fabric of our society there are times and situations during the development of some children/youth with complex needs, be it social/emotional, behavioral, mental health issues and/or developmental needs, that require an intensive educational setting outside the general education classroom. Therefore it is imperative that we continue to abide by the federal regulations that ensure the most appropriate setting (least restrictive) which may include a program specifically designed to address these needs. It is no different within the medical world – some illnesses require an intensive regimen of intervention in a specialized setting with staff who are trained and experts in the protocols to address their patient’s needs.

       It is essential that we continue to provide a continuum of services that meet the diverse needs of our youth and ensure that they receive the best interventions to support them in maximizing their potential. This in no way precludes most of the youth with disabilities from an inclusive setting.

       I provide my response as both a parent of a former youth who benefited only when he was provided a non inclusive educational setting and as a special educator working in the special education arena in both the public and private sector since the early 1970’s. Unfortunately I have experienced hundreds of youth who have been negatively impacted when forced to remain in a general education environment that is not addressing their needs. Some of these results have been devastating.

       It would be seriously detrimental to create policies that do not reflect the significant needs of many youth who simply have not had their educational needs met in the general education setting. The least restrictive environment is different for some and at different times in their development. I urge the Department to focus their efforts on ensuring that all youth with disabilities have full access to the program that is most appropriate for their needs and is a part of the continuum.

283. As the mother of a son on the autistic spectrum and a physical therapist who has previously worked with this population, I see full inclusion as the ultimate goal for any educational program. When appropriate, each child should be placed in a least restrictive environment to attain developmental goals as early in life as possible. However, I fear that without the professional assessment and full range of options for placement that now exist, many children will be forced into less than optimal programs and outcomes will suffer. My own pre-school son spent 3 years in a most restrictive environment that was so successful, so tailor-made, that he did not require an IEP after the age of seven. Though the government made an initial substantial investment in my son, the rewards have been great. Not a penny of local, state or federal funding has been spent on my son’s education since first grade and he is currently attending Georgetown University. Kindly allow these most effective educational settings to survive for the neediest of our children. A spectrum disorder requires a broad range of available interventions. High quality programs that include most restrictive environments may save MONEY and improve OUTCOMES in the long run.

284. On p. 4 in the second paragraph under The Legal Foundation for Inclusion, the wording about children with disabilities served in Head Start and EHS should reflect the language from p. 19, the 2007 reauthorization, which is stronger “not less than 10 percent of the total number of children actually enrolled by each Head Start agency……” As someone who worked with my State Department of Education as a Regional Preschool (and sometimes birth – five) Coordinator for 14 years, this all looks SO VERY familiar. We pushed for itinerant Special Instruction (and related services) services to be embedded in the classroom instruction in coordination with the classroom staff. This has been slow to happen. How are systems held accountable for this? By the same token, I do believe that a continuum must continue to be offered until “high quality” ECE slots are available for all children. Coming from a state with a high poverty level and its attendant problems, many children with disabilities need a “structured preschool environment” that is high quality. The only entity offering such a program in some locales may be the LEA with their self-contained early childhood special education classes. If there are a limited number of 4 year old classes for at-risk children in a county, then every child with a disability that is taken out of ECSE classroom and put in 4 year old class as his/her LRE is essentially taking a slot away from a child with risk factors but no identified disability. There is still a quality gap when you rate early childhood programs. Some have more highly qualified and better trained staff than others when it comes to serving children with disabilities. The gap is being narrowed in the Head Start/EHS arena but some child development centers may be lagging behind in their inclusion skills. To push children toward those slots in an at-risk program by a system’s change may not be doing the students a favor. In our state we have dismantled much of the training and TA network that used to exist and push these initiatives. The LEAs have such a burden on them to meet all the child outcome assessments, I fear more unfunded mandates will not be welcomed. This policy statement reflects what I believe but the devil is in the details–how will this be operationalized. Thanks for pulling together this policy statement. I hope it has its intended effect.

285. As an individual whom has attended a continuum of educational placements, there is no question that I wholly positively benefited from attending a school for the deaf. I did not truly experience “inclusion” in an educational setting until my attendance at a deaf school. I urge DoED to expand its policy statement to specifically reference deaf educational programs as part of the continuum.

     In support of explicitly recognizing deaf education in the statement, I also urge us to heed the guiding principle in Article 24 Section 3(c.) of the Convention on the Rights of People with Disabilities:
     “Ensuring that the education of persons, and in particular children, who are blind, deaf or deafblind, is delivered in the most appropriate languages and modes and means of communication for the individual, and in environments which maximize academic and social development.”

     • Jeff Rosen said it all, Convention on the Rights of People with Disabilities. Deaf children are visual learners and benefit from direct communication with teachers who use American Sign Language as mode of communication, it is one of most used education program in continuum.

     • I fully support this comment. While many other disabilities will benefit from a mainstreamed environment, Deaf children do not. As a matter of fact mainstreaming is often total isolation for a Deaf child. This is mentally and emotionally damaging. I am in support of Mr Rosens view of continuum of educational options for Deaf and Hard of Hearing children.

     • Excellent comment. With “inclusion” becoming the buzz word for all that is fair and equitable, Deaf/Hard of Hearing Teachers are seeing some of students actually excluded when they are in a general ed environment. Excluded from signing peers, from smaller more acoustically appropriate environments, and from cultural mores that only exist when Deaf/Hard of Hearing kids can be together in a class. Isolation because of communication barriers is actually exclusion. We need Deaf/Hard of Hearing individuals to stand up for their rights of communicative inclusion.

286. I am thankful for the draft policy created by the U.S. Department of Education (DOED) and the U.S. Department of Health and Human Services (DHHS) regarding inclusion of young children with disabilities in high-quality inclusive early childhood programs, and hope this becomes the required policy as soon as possible. My background as a teacher first prepared me in the role I would take for my child with Down syndrome. The role of parent gave me first-hand experience observing our daughter’s unique needs and addressing those in our least restrictive environment of family and home, in order to pave the way into preschool communities. We were pioneers and advocates teaching others as we were taught about the needs of our child, by our child. We have practiced full participation of inclusion as family and school partners, from preschool throughout elementary school, and are ready to launch into middle school. Of course we expect our child to enter society as an adult in the future. She will not be separate in life, but immersed in her community and interest areas as a fully functioning adult offering her talents and skills.
     Inclusion must be a collaborative effort by all key players in educational systems and support systems, and involve public awareness in order to affect change through advocacy and understanding. A child’s specific school setting lasts a short span of time and must be facilitated by the best teaching practices and learning for all involved. Children will take away lessons learned in preschool, elementary school, middle years, and beyond. Their very existence will be shaped by the standards and settings they are placed within. Let those be the most valuable and rigorously tested to create individuals who contribute to society with the best of their abilities of compassion and intelligence.

287. Absolutely not, it is sometimes not for all Deaf and Hard of Hearing Children. One size does not necessarily fit for all of them. At times, we must place them together in the same classroom, to preserve their language of American Sign Language and use the language as part of their acquisition. Please be careful of what you write, into educational laws.

     • I agree! Thanks, Lisa Purnell.

288. As being Deaf myself and I also speak for the Deaf community anywhere in USA, I strongly agree with James Tucker’s comments about the draft, “The Policy Guidance draft must include provisions for Deaf and Hard of Hearing infants and toddlers to ensure that they achieve language benchmarks in American Sign Language and English. Thousands of Deaf and Hard of Hearing children become language-delayed as a result of “inclusive settings” where they are unable to fully access language models”. What is more? It is a big mistake to make this policy without getting input from the Deaf communities as well as from the DEAF Heads of various schools for the Deaf. Thank you for listening.

289. Thank you for initiating a concern on early child education however I foresee a problem with full inclusion for deaf children. The policy statement on inclusion of young children with disabilities in high-quality inclusive early childhood programs may work for other disabilities but for deaf children, the academic level varies and the same goes for hearing loss ranging from mild to severe. One size does not fit all so I seriously suggest doing a case study to understand conclusions where facts and statistics play a part.
     Thank you for listening.

     • I am concerned with the policy statement on Inclusion of Children with Disability in Early Intervention and Early Childhood Programs. Inclusion is not a benefit for deaf and hard of hearing because of greater difficulties with communication with peers in general education settings. Deaf children will always be isolated in any intervention and early childhood programs because they always are left out of groups, activities, classes, and sit alone in the cafeteria. It’s unavoidable, because teachers, interpreters, and hearing students can’t communicate the way they want deaf students to, and they still don’t understand them.
       I support IDEA that requires the child to be appropriately evaluated by evaluators and Individual Educational Plan team. They develop appropriate goals and needs for deaf and hard of hearing. High quality programs that include least restrictive environment save MONEY and improve outcomes. Deaf schools give deaf and hard of hearing children full access to full language and communication and equal educational opportunity. They have raised expectations for what children can achieve education and language and meet the learning and development needs of all children. I am proud of my two deaf and hard of hearing children who graduated from college. My hard of hearing daughter will be a third-year law student in the fall.

     • I totally agree , kinda like have one med would cure all ?? Same with all deaf and ddh- put in one corner? Do they do best interest for us all or just push us in easy way than deal with .. We are not a puppet – we re human being. Agree with your statement.. Would like them do research and put all notice to all parents voice out their opinions about their deaf and ddh children , and Disabities even thoughout deaf school and dhh – hearing mainsteam with interpreter provided.

290. The Massachusetts Department of Elementary and Secondary Education’s 619 Program is pleased with the policy statement on the inclusion of young children with disabilities. The document is thorough and is useful for state and local education agencies.

     Massachusetts would like to add the following link and paragraph to the section entitled:
     Appendix 3: State-Developed Resources to Support Inclusion.

     Massachusetts has collaborated with families, special educators and administrators, other state agencies, and community partners through authentic stakeholder engagement activities to create a mission and vision for Early Childhood Special Education (ECSE) that outlines the Department’s belief in individualized supports and services promote young children’s participation in the general curriculum and all aspects of the school.

291. My son attended a preschool called the Karen Slattery Educational Research Center for Child Development at Florida Atlantic University. He was a student in the first class of 3 years old in 1990 alongside his typical peers. Today he is a post-secondary program college graduate who works in competitive employment in a job of his choosing and lives in an apartment in the community with a roommate. He also has Down syndrome. YES…I believe his early years inclusive preschool made all the difference in building a foundation for the education that was to come next for him.

292. 20 years of research clearly showing the benefits of inclusive education for all students is not wrong! Regardless of the disability, all children benefit from have positive peer role models, a language rich environment, and feeling accepted as part of society. That we are still having this discussion is so frustrating to parents who know that with the appropriate supports, their child would thrive in an inclusive setting. Segregating any child based on outdated models and thinking is doing them and us a tremendous disservice. It sets them up for a life skills track of schooling with low expectations and doesn’t properly prepare them for the real world. Life is not a self-contained classroom. If done properly, the class size and ratios and funding should not be a problem. Why should parents of children with special needs have to fight for their child to be accepted and given a FAPE with the necessary modifications and accommodations? Thank you for the opportunity to comment and I support this policy statement.

     • I am a strong supporter of inclusion programs for early childhood education. My son turns three this summer, and he has Down Syndrome. As we have started going through the public school placement process, numerous school personnel have assumed he should be placed in a self-contained classroom before they have even met him or reviewed any of his assessment results. I find myself constantly advocating for and explaining the benefits of inclusion. My son is doing great, and I firmly believe his development has been aided by being placed in an inclusive daycare to date. I strongly believe he should be placed in inclusive early education programs, and I am hopeful that this policy statement will help him attend those programs and achieve his full potential.

     • When stating ALL you must remember ALL also includes Deaf, deaf/blind and hard of hearing children who are often in the most restrictive environment when it comes to “inclusion”. For them this “inclusive” environment is language deficient, does not include ASL language models or peers who speak their language. It can and research has shown that this environment can create a huge language delay as well as limited opportunities to be in an environment where communication is automatically accessible therefore automatically becoming a very restrictive environment.

293. I would like to see language in the draft statement that reflects the fact that inclusion in early childhood is not just good for children with disabilities, but for the typically developing children that are a part of these programs. Early Childhood Inclusion leads to young children who are more tolerant, empathetic, and accepting of differences. These are key qualities to encourage in our youngest citizens in this ever increasingly diverse world that we share.

294. The National Association of State Directors of Special Education (NASDSE) applauds the Departments of Education and Health and Human Services for jointly issuing this very strong statement on the importance of including young children with disabilities in inclusive pre-school settings where they can develop alongside of their nondisabled peers and on behalf of the state directors of special education, we thank you for putting this document out for feedback. It is important for all early childhood providers – regardless of where they are housed – to understand the importance of inclusion and to take appropriate steps to make their setting welcoming to all children.

     NASDSE is pleased that this document recognizes the need for community-based strategies and includes specific steps that communities and individual programs can take to make preschool environments welcoming to all children. We applaud the Departments for not including in the document’s definition of inclusion in early childhood programs a specific number or percentage of children with disabilities for a program to be considered inclusive. Because programs vary in size and the needs of an individual communities also vary, setting specific targets or numbers will take the focus off of the very important needs that individual programs have in order to be more inclusive. The goal should be on creating welcoming environments, where the early learning professional staffs are trained to meet the needs of all children, including those with disabilities. We welcome the recommendation about communities having trained specialists who can go to individual facilities to help assist with professional development and specific strategies to address the needs of all children.

     We do have two specific suggestions for inclusion in the document:

     1. We highly recommend that the document include definitions of terms that not all readers of this document may be familiar with, specifically terms such as positive behavior intervention and supports (PBIS) and early childhood mental health consultation models (ECMHC).
     2. Under the Resources section in Appendix 2, we suggest adding links to Part B, 619 and Part C state agencies so that parents and early childhood professionals can find information on these programs in their own states. Links to the 619 and Part C programs can be found on the website of the Early Childhood Technical Assistance Center (ECTA) at http://www.ectacenter.org and links to the Part B state agencies can be found on NASDSE’s website at http://www.nasdse.org.

     Finally, NASDSE recommends that ED and HHS work together to widely disseminate this document to get it in the hands of early childhood professionals as well as other state and local stakeholders. We suggest tapping into the networks of professional organizations such as DEC, NAEYC, NASDSE, ITCA, CASE and the National Head Start Association as well as posting on the websites of the relevant technical assistance centers funded by ED’s Office of Special Education Programs (OSEP) such as the DaSy Center, ECTA and others.

295. In my opinion the U.S. Department of Education has interpreted IDEA inappropriately. The promise of IDEA was to ensure that a continuum of options were available for infant/toddlers and children for individual plans that would meet their unique needs while satisfying the mandate of natural environment (Part C) and LRE (Part B). This opionion paper seems to disregard these unique needs by suggesting that all children with disabilities can be appropriately served in one type of setting. I have had the priviledge of serving disabled children and their families (between the ages of birth through five) in New York State for the past 35 years. As one of the first male kindergarten teachers my interest in the earlist intervention was born out of a realization that in 1973 no integrated services were available for children with disabilities between the ages of birth through 5. When my school opened its doors in 1980 New York State (like so many states) had no idea how to support the mixture of funding that comes with including chidlren with and without IEP’s together. I found myself fortunate that New York State supported “mainstreaming” long before our national landmark legislation. Today, 77% of the Just Kids children with disabilities have the opportunity to take part in our integrated classroom program with children without disabilities. Children identified for our classroom program have significant needs. “The therpeutic nursery school” at Just Kids is quite different then Head Start or other excellent early childhood programs. Our programs are staffed with full time clinical support staff and NYS certified special education teachers who, by their licensure, ensure a minimal understanding of the complexities and therapeutic startegies that are needed to truly promise a meaningful
     change in the attainment of IEP and IFSP goals. Certainly the hands on experience that staff gain from working in a highly superivsed environment facilitates our ultimate goal to define them as expert clinicians and teachers. Our programs are not meant for everyone. Children with less significant needs have similar success in less specialized enviornments. Just Kids recognizes that some of our children must start out in more restrictive environments in order to attain the skills that are needed for success in our integrated classrooms. It is a shame that programs like Just Kids who have been identified as both a special education program as well as an Office of Children and Families approved day care are categorized through our state performance plan as more restrictive then other early childhood programs. We now see approximately 1500 children per day. Half of our children have IFSP or IEP contracts. The other 750 children are typically developing. We must ensure that all of our children; whether disabled or non disabled have the same ability to acquire skills and find equal success in our program. Data that is provided to OSEP by our SDOH and SED agencies (through our SPP) seem limited by the federal data software that does not recognize this integration when the pre-school provider is designated as a PL 4410 pre-school. It is interesting to me, to note, that when a child turns 5 and finds themselves in a separate classroom within their public community school LRE is satisfied. When a child in New York State is included in the same classroom as his or her non disabled peers, LRE is credited to New York only if that takes place in a Head Start or another nursery school that is not approved as a PL4410 program. Today, many of our children come to us with a strong social /emoitonal need. It is imperative that we have the support necessary to address these needs. My fear is that this “policy statement” will further segregate the lives of children and families whose dream was founded in the passage of IDEA. Thank you for your consideration.

296. As an individual who received early intervention support services, I cannot emphasis how critical it was for my language development because it was provided in a one-to-one setting and group settings with other Deaf students in American Sign Language. In addition, my parents received information from the early intervention specialist that contributed to my education. I am concerned that early intervention support services will slowly phase out over time due to the proposed policy which put a greater emphasis on inclusion of young children with disabilities. I urge the Department of Education to reconsider its position on inclusion and least restrictive environment for Deaf education because the approach does not work.

297. I know first hand the benefit of inclusion in an early childhood setting. We were lucky enough to find a daycare that included my son and I know that everyone benefited from it. I applaud the authors of this statement for bringing the urgency of the situation into words. I fully support this and hope that our legislators will head the call. In my quest for a kindergarten for my son, I have been disappointed in the number of schools with a truly inclusive setting. Hopefully if this policy can be implemented the great society will no longer by apprehensive but rather excited about inclusion. There are no drawbacks only developments!

     Lauretta

298. Thank you for the time and effort that was put into this policy statement, however as a speech-language pathologist working with children who have a various communication needs, this policy statement does not address the needs of a low-incidence, but certainly important group: Deaf and hard of hearing children. Language deprivation is a serious and prevalent issue in Deaf and hard of hearing children regardless of the type of amplification that they receive and the supports that are given to them. This reality can be prevented by offering a continuum of appropriate placements, as mandated by IDEA. The continuum would include special classes and special schools. Any placement on this continuum, regardless of f the types of communication options/interventions that are right for that child: American Sign Language, auditory-verbal modalities, other types of signed languages, cued speech, etc. would then not be considered the lease restrictive environment. This document incorrectly assumes that least restrictive environment is always the general education education environment, which is simply not the case for Deaf and hard of hearing children.

299. The field of ECE is disjointed. Most of the people working in CHILD CARE programs have only minimal educational background and training. They often make minimum wage. Their qualifications come from state child care licensing systems designed to ensure that a parent can be assured that their child will not be injured while they are in care. This all stems from the history of child care being about work support and not about child development.
     Until people are better paid they can not be required or expected to get the education outlined in this brief.
     However, there are people in the field that work in publicly funded programs such as State-Pre K or the early intervention system where they do make a living wage and they do have education. However, because the system is bifurcated the training is as well. You must realize that some state credentials, used in the child care part of the system are not based in higher ed but are community based and not offered for credit. Bottom line, until all people working in ECE make a living wage, you will never get the personnel prep needed to meet these goals.

     In addition, you need to address the federal funding disconnects. Health and Human Services fund child care. Education funds Part B. Get Education dollars to fund ECE, or at least use the cost per child that goes to kindergarten to support children in child care, and you would have these problems solved.

300. It is very important for all children to have access to high quality education beginning in pre-school. This access must be considered a natural right for all children. Currently all children and specifically children with disabilities do not have access to high quality pre-school. Therefore, mandated inclusion is a necessity for all children to have access to high quality education. This does not mean that all children and families will opt to place their child in a high quality preschool and that is their choice. The fact of the matter is that to make access available to children with disabilities, we must make it a mandate that all children are to be included and the necessary accommodations and supports will be provided to make that happen. Families can then make a personal choice of what pre-school option works best for their child. Sadly, if we don’t make access to quality pre-school for all children a right, then it just won’t happen. I have a personal story to share. I have a child who has a disability who has been attending pre-school at a private community pre-school for about 2.5 years. She has been doing great in her pre-school and has fit in seamlessly with her peers. She fully participates in activities, circle time, etc. Her teachers and peers love her. Everyone has benefited from her being included. She makes the classroom a better place for everyone. Sadly, just yesterday I was told by the school administrator that my daughter is no longer welcome at the school. Simply put, this is because she has a disability. Even though my daughter has never had support needs in the classroom beyond what all children have, (ie: help washing hands, reminders to pick up toys, etc.) the administrator fears that she may need support in the future (complete hogwash) therefore, since there is very remote potential for some unforeseen support need, my daughter is no longer welcome at the school. I tried to offer suggestions for ways that we can remediate this fear that the administrator had of unforeseen support and how to handle those mysterious supports should they arise but was told there is no way my daughter can continue at the school. Needless to say, it was a heartbreaking slap in the face after having her fully included in a typical preschool classroom with no support for 2.5 years. My daughter deserves to have access to a high quality education and because she experiences disability that is no longer an option at this particular school. Had there been laws to protect her, this would not have happened and my daughter could continue at her school with her friends for another year where she would continue to set an amazing example for what is right and touch lives. I will be home schooling until kindergarten starts for her in 2016. My daughter has done amazing and I feel that had she been segregated into a disability only preschool she would certainly not be doing as well as she is. She is just a typical kid that deserves what everyone else has. Please change legislation so that an inclusive education is available to all children whose families choose that option for their child.

301. Thank you for the draft and opportunity to comment.

     The recommendation to braid funds seems to address the unknown risk. In other words, it may actually be less expensive.

     Also, please consider if flexibility is intended. Integration of guidelines may provide for expansion on the basis of structural need by region.

302. I am a Speech-Language Pathologist from Seaford, NY and I have worked for the past 27 years treating special education children between 18 month old to 5 years. Each child with a disability is unique and each may require a different setting to learn successfully. A policy such as proposed on full inclusion is not in line with law and regulation and takes away the placement decision from the parents and professionals comprising the IEP/IFSP teams. The proposed policy would remove options on the continuum for students who are most appropriately served in a variety of different settings. This policy suggests a “one size fits all” model and does not support the civil and educational rights of students and parents who are promised the continuum of services be available, as necessary, to meet the needs of individuals with disabilities. IDEA is a well written law that needs to be accurately implemented to ensure that ALL students with disabilities continue to be served appropriately.

     • I agree with you. I have seen inclusion work very well, as I have been an inclusion teacher. One problem I have seen for example, there was a 3 year old who screamed most of the day and had numerous outburst throughout the school day. This behavior interrupted other students from learning. Sometimes, some of these children with disabilities, cannot handle (nor can the general education teacher) being served in an inclusion setting, therefore I don’t think the law should state total inclusion. As said before One size does not fit all.

     • In Waco, Texas there was ASL class course with the deaf teacher. After hearing students took this course from local home address but one student was from Austin, Texas 90 miles to drive for this class. The deaf teacher noticed and watched this guy because of 1 1/2 hours driving. After few weeks, the guy was as “deaf sinner” that their family in Austin required this student under speech or oral method daily – No sign language all times. So the student had hard time to use oral method so ASL is very popular. So the deaf student went periodic class with the hearing local area students did not know very much this student. Shh! After each class session , student went home back with their family without ASL or hidden secret. Clearly it was very hypocrite. Why not to attend Texas School for the Deaf or ACC or UT campus easily. Contact with us to discuss better and deaf/HH history there. I was stayed in College Station, Texas for one year among hearing students so I was back to TSD campus to complete my education next year. Please remove off LRE off. I asked my deaf teacher why he did not mention dark period in the past to me as my deaf father mentioned a lot. He replied me, “All teacher’s jobs were all times to give good history but not incidents and kept hidden. So They think okay with the current policy. Study deaf history in USA better. Remove LRE off from them and restore all deaf/HH students better. Read the deaf authors’ books please.

       submitted by
       Samuel E. Jones TSD ’67

303. I have spent all of my adult life, working with Deaf and Hard-of-Hearing children. This new bill, if passed, could have a devastating effect on the lives of so many. The term “least restrictive environment” may mean the public mainstream for many children with a variety of disabilities, but not for D/HOH children, especially very young ones. Even those who are exceptionally bright, are identified early and have had all the right resources put in place, often describe their mainstream experiences to be challenging at best and at times, terribly isolating and difficult. D/HOH children are not just children with “broken ears”. They require specialized instruction from teachers who are trained to work with them. They need D/HOH peers and role models in order to develop positive self-identity and pride. As it is now, children are often placed in their public schools, without adequate support and flounder until they are lucky enough to be placed in a specialized program. Often, they have developed overwhelming delays and low self-esteem. Imagine being placed in a situation where you are surrounded by teachers, curriculum, typically hearing peers and social life that is not accessible to you! This policy is “penny wise and pound foolish” for so many reasons! Please do not allow this bill to pass in some misguided ideas of “inclusion”.

304. There should not be a policy on inclusion, policies should follow the law and it should only say LRE/Natural Environments and placements that are approved by the IEP and IFSP Team, anything else will prevent children and students from being served appropriately. The law ensures that ALL students are served based on their individual needs, it works if implemented correctly. This policy is trying to push one placement over another, this is not OSERS responsibility, this responsibility belongs to professionals and parents. Please help to appropriately implement the current law, not set policies that contradict current law.
     There are many students who this is not going to work for and it isn’t working now for some of these children. It is important that the services be provided in the appropriate environment early, not simply having ALL children in a one size fits all system. Each child is an individual and the decision needs to be based on that child’s needs, not a blanket statement for all children.

     • Yes, spot on. Great comment.

305. Individual Educational Plan is clearly child needs-driven. Deaf (definition including all deaf and hard of hearing students) as a disability is least known due to low-incident, thus the challenge of meeting the communication and related needs of a deaf child often is beyond the capacity in a regular educational setting. Research repeatedly shows that LRE for deaf students should be viewed in a paradigm of Language Rich Environment (LRE). The definition of this paradigm is already elaborated through Dr. Davila’s work (considering factors in determining placement of deaf students) and clarifies the FAPE for deaf students.

306. I am in opposition to The U.S. Department of Education and the Department of Health and Human Services draft policy statement regarding inclusion of children with disabilities in early intervention and early childhood programs.
     I am the Executive Director of the American School for the Deaf, the oldest special education institution in the U.S., the birthplace of deaf education in in America and American Sign Language. In 2017, the American School for the Deaf will celebrate its 200th Anniversary. Being a deaf individual myself, I can speak from experience on the educational landscape as it pertains to deaf students.
     Unlike other disabilities, deafness is both low-incidence and often misunderstood. The mitigating factor that separates deafness from other disabilities including blindness, mobility issues and intellectual challenges, is language and communication accessibility. It is widely agreed by educational professionals that early access to language is vital to the intellectual development and success of all children, but is especially critical to deaf and hard of hearing children.
     Specialized schools that serve deaf and hard of hearing children employ qualified professionals who are trained in various methodologies designed to meet the unique learning styles of deaf and hard of hearing leaners. Deaf children acquire language and learn differently that their hearing peers. They are visual learners and do not have access to the same ancillary opportunities to acquire language (television, radio, spoken language) that hearing children do. Language and literacy need to be presented to these children in a manner that fits their learning style by professionals that have the training and experience to ensure success.
     Try to imagine a child without the concept of language being placed in a program with an interpreter. If the child has no frame of reference, nothing the interpreter is signing makes sense and the child begins to lose ground almost immediately. Catching these children up becomes a challenge that often leaves the child with lifelong language deficits.
     The U.S Department of Education often refers to the Least Restrictive Environment as a goal for student placement. The argument is often made that this is and should be the public school in the child’s home district. I could not agree more; with one notable exception…the child MUST have full and equal access to language development and literacy. Additionally, they must be taught by trained professionals, and it is beneficial for them to have a peer group with whom they can socialize similar to their hearing peers. I would argue that for young deaf children receiving early intervention services or being placed in an early childhood program, the least restrictive environment is one that is communicatively accessible. The LRE for young deaf children should be programs and placements that allow for the development of language and literacy.
     The average age of admission at the American School for the Deaf is trending upward from age 12. Unfortunately, we see children who have literally failed through the public school system and come to us with such significant language deficits that it is nearly impossible to bring them up to grade level before they age out at 21. The children we see that enjoy the most success and typically continue with post-secondary education are those who began with deaf-focused early intervention and early childhood services. On many occasions, the U.S. Department of Education has stated that, “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the least restricted environment (LRE) for that child. Just as IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular education setting when the child’s need cannot be met in that setting.”
     In light of irrefutable evidence that deaf children learn differently than their hearing peers and need appropriate access to language and communication taught by trained professionals in order for them to be afforded the same opportunities as their hearing peers, I would strongly encourage the U.S. Department of Education and the U.S. Department of Health and Human Services to maintain the language and spirit of the existing IDEA legislation and allow children to receive services and be educated in the most appropriate and beneficial environment.

307. I am a Speech Language Pathologist and work with preschool aged children who have special needs including language and learning impaired and children who are on the autism spectrum. When working with children who have special needs our ultimate goal is to help them progress enough so that they could hopefully be mainstreamed into less restricted environments. However, the path to inclusion is different for every child and we can’t adopt the idea of a one size fits all mentality. We need to think of each child individually so that his/her needs can be best met so that they can reach their maximum potential. Professionals who work with these children and their parents know the children best and know what things will and won’t work to help that child succeed. It is important not to confuse IDEA with inclusion. IDEA was meant to take each child’s individual needs into account and if you adopt an inclusion model for all children who may not be ready for it, that child will not succeed. Isn’t that the goal of us as educators? To see our children at all levels to succeed?

308. I am a parent of two highly educated Deaf children: one is a junior at Kansas School for the Deaf, and another one has just graduated from KSD last night with honors. It is all because they had a HIGH QUALITY Early Childhood Education as toddlers where the teachers and staff were trained in the area of educating the deaf. It is especially important in deaf children’s formative years (ages 0-13) for them to have a barrier-free access to language and communication, so that their cognitive, academic, socioemotional and physical development come to a complete fruition comparable with their hearing peers, hence the need for Individuals with Disability Education Act.

     In IDEA, public agencies are required to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. The inclusion document by OSERS incorrectly assumes that LRE is always the general education environment.

     The U.S. Department of Education has issued policy on many occasions stating “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Research shows that deaf and hard of hearing children who do best are those who are identified early and receive appropriate early intervention from specialized providers. These providers typically are not found in general early childhood programs.

     Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

     Thank you.

309. Continuum of educational placements is the law! Deaf Education is not Special Education. Special Education is not Deaf Education. The Policy Guidance draft must include provisions for Deaf and Hard of Hearing infants and toddlers to ensure that they achieve language benchmarks in American Sign Language and English. Thousands of Deaf and Hard of Hearing children become language-delayed as a result of “inclusive settings” where they are unable to fully access language models.

     Please read page 7 in The Maryland Bulletin (Winter of 2014-2015 issue), a publication of the Maryland School for the Deaf:

     http://www.msd.edu/mdb/current.html

     Also, please read page 12 in the Maryland Bulletin (Spring of 2014 issue):

     http://www.msd.edu/mdb/v134i3_14_spr.pdf

     James E. Tucker
     Superintendent of the Maryland School for the Deaf
     President of Conference of Educational Administrators of Schools and Programs for the Deaf

310. To Whom It May Concern,

     I apologize if this email seems long, but just received this via the KY Educational Interpreter ListServ, and don’t have much time to edit, because comments are due TOMORROW, May 22, 2015. I know each of us has had personal experience on this topic. I know that when my son, Mick was young, the full spectrum of options were available *except* placement in our home district with a SEE Interpreter. That was always a fight, but sadly, when he had a true qualified, certified SEE interpreter, he thrived in that environment.

     It appears as though some militants are trying to kill this bill, citing that The School for the Deaf is the best placement, according to LRE, and that may well be true…for SOME, but the academic outcomes reports do not support this position. Access to language for Students who are deaf or DeafBlind does not always mean ASL. American Sign Language (ASL) is recognized as a foreign language, as it has grammar and syntax that are not the same as the English language. In fact, there is an entire continuum of signed languages that must be considered, (I have attached a diagram), especially in the cases where that signed language is used and supported with a commitment of the parents or guardians in the home from birth until and including throughout the child’s educational career. Use of that language is optimized when there is a concerted, coordinated and consistent use of the chosen AND SPECIFIED language modality between home and school.

     My deaf son (who is now 33 years old) grew up using Signing Exact English, he acquired the English language via this method, and the current research presented by Leutke, et al that Signing Exact English supports English language AND morphemic awareness acquisition is certainly applicable in Mick’s case, although he and many children like him are not documented in most or all studies. For some ridiculous reason, “the powers that be” decided that, when the Deaf President Now protests occurred in 1988 that my son’s “language” was not English grammar and syntax, but that it should be switched to the grammar and syntax of American Sign Language (ASL) because “he is deaf and this is his language.” My son struggled in school after that *except* when he was given a certified SEE interpreter or teacher who used SEE. Keep in mind that my husband and I are fluent SEE signers, and our son had full access to this visual mode of the English language at home and whatever community event or activity in which he chose to participate. At school, we begged his school administrators to give him a SEE interpreter for his classes, but we were refused that, citing that they had to give him an ASL interpreter, because the another student in his class used ASL, and “that’s what is used in the Deaf world, and so we should just get used to it.”

     Nothing could be further from the truth. I have been a certified educational interpreter for the deaf since 1988. I have provided services for many deaf students and adults over the years, who prefer to use a SEE interpreter. These students and adults are constantly marginalized by a loud minority of students who are programmed to believe this is true at all-deaf state schools and universities, and these ideas are perpetuated by “ASL studies” and so-called “Interpreter Training Programs” who dictate that ASL is the ONLY signed language of signed system used by deaf people.

     This attitude puts deaf students in a “one size fits all” box, and THIS is not only unethical to FORCE a language choice on deaf students and/or deaf adult consumers, it violates their right to access communication in *the language most readily understood.” This access happens tactilely for some, in Signing Exact English (SEE) for some, and in American Sign Language (ASL) for some. Appropriate placements must take into consideration the educational goals, and supported by parents/guardians in the home AND at the school of choice.

     NOTE: there are studies that show students who have received their education via SEE interpreters have achieved successful educational outcomes – they typically take their state standardized tests and/or ACTs with accommodations for verbal instructions only. They are able to read English, however, and do not require an ASL translator. These students are not identified in the test exceptions report, because they take the test independently. These students navigate through the system, and often attend the higher education institution of their choice…not necessarily an all-deaf college, but ANY college of their choice. They request accommodations after acceptance, so that the college they choose cannot turn them down for “some OTHER reason’ when in fact, they don’t want to incur the cost of the accommodations for access to language. I have seen this “game” as a mother and as an Educational interpreter and DeafBlind Intervener. I have seen college deaf and DeafBlind students and adults, (and parents, guardians and families) request SEE Interpreters, and are denied these accommodations, citing “Deaf adults use ASL.” This is simply not true, and something needs to be done to stop this form of reverse marginalization that has somehow created this chasm and miscarriage of the intent of the ADA and IDEA.

     The language used must be consistent if the educational outcomes set forth are in consideration of:
     -the child’s unique needs and abilities
     -the MODALITY of the signed language to be used must be specified in the IEP as SEE, ASL, Cued Speech, Total Comminication, Oral Transliteration, etc. (Most administrators will not allow this, but it is VITAL to educational outcomes!)

     PLACEMENT OPTIONS MAY BE ANY of THESE:
     -a mainstreamed home district school setting with appropriate accommodations (certified SEE interpreter, certified ASL interpreter, certified Cued Speech provider, certified DeafBlind Intervener, etc), as well as technology and note takers/transcribers as needed. This is often an option that families who choose to have their deaf children educated with English language goals and objectives may choose, because this option does not exist in Residential Schools.
     -placement in a special day class (SDC) may be available in a given region, but this is not always available. (It should be!) Parents may choose this educational setting because of certain “communication policies” that exist in these settings. (This communication policy may be SEE, ASL, Oral, Total Communication, etc), and all teachers, interpreters faculty and staff – even the janitors sign using the specified language modality, and parent signs a communication philosophy and agrees to support the student in this modality.
     -placement residential school for the Deaf (especially important for those students who are generationally deaf (5% Of the population of Deaf students are born into deaf families) or those who wish to raise their children in the Deaf Culture using ASL consistently across all settings. In this case, all administrators, faculty, staff and students are expected to use ASL.
     * in the case of students who are DeafBlind, appropriate accommodations could be any of the above, but may also be accommodated at a School for the Blind, so long as additional accommodations are implemented to meet the unique needs of these students, which may include a certified teacher of the DeafBlind (as opposed to a teacher of the deaf and a teacher of the blind…DeafBlindness is unique…one specialist puts it well: “It’s not Deaf PLUS Blind, but it is Deaf TIMES Blind.”) Some of these unique accommodations may include an Interpreter who is trained in DeafBlind interpreting (not all interpreters for the deaf are able to interpret for DeafBlind), a support service provider (SSP) and/or a DeafBlind Intervener all who are specialized and trained to provide certain levels and techniques that are UNIQUE for people who are DeafBlind to access auditory, visual and environmental information within their educational and/or community-based environments.

     These, as I see it, are the truest form of appropriate accommodations and access to language *most readily understood* according to the unique needs of each child with a continuum of access to language and learning environment placement options that need to be taken into consideration in order to meet these needs. All options should be made available within specified regions of each state, so that this piecemeal, patchwork of educational options does not continue to send the wrong message. The education and vocational needs of people who are deaf or DeafBlind is NOT a “one size fits all” solution. I believe it is high time that the IDEA and ADA set forth the true options that exist within the language of these documents, so that families, administrators and systems that are responsible for providing access to services are no longer allowed to marginalize or minimize the potential that these students are capable of achieving, when their INDIVIDUAL and UNIQUE needs are truly supported.

     Sincerely,

     Barbara J Martin, AS, ESSE:I, EIPA, RID
     Parent of a (now) Deaf Adult
     Certified Educational Interpreter for the Deaf
     DeafBlind Intervener
     Instructor: Signing Exact English
     Educational Consultant
     BSW/MSSW student: University of Louisville

     • I don’t think that this is the appropriate forum for debating communication options. No matter what the mode of communication is for a Deaf and hard of hearing child, this policy statement is assuming that a general education environment can appropriately serve all students, which is simply not true.

       • Barbara Martin- Your labeling, as “militants”, of those many excellent comments from very qualified Deaf professionals across the nation whom many of us respect and the valid comments of members of the Deaf Community who have LIVED the experience is OUT OF ORDER.

       • Thank you, Janet for your comment. It is the same point that I was going to make. I also think it is extremely inappropriate to label those who are concerned over the one size fits all ideology that this pushes for as “militants.” It carries a very negative connotation and is disrespectful to advocates and deaf people who are fighting for quality education for people who are deaf.

         With that aside, I would like to express my opposition to this policy as a parent of a deaf child, a child of deaf adults, a former educator of deaf children and a current sign language interpreter. Inclusion does not address all the needs of children who are deaf. As many commenters have stated, children who have different abilities need a approach to education the addresses the needs of the whole child – academically, socially and emotionally. Inclusion does just the opposite. This forces many deaf children into a very restrictive situation. While their hearing peers are full participants in the educational experience, many deaf children are left out. My daughter who is profoundly deaf and who is intellectually gifted is attending a school for the deaf where she is able to participate in classes that are stimulating because she is able to engage in discussions in a natural more fluid manner than she would in an “inclusive” setting. She is also a cheerleader. Should she be able to be a cheerleader at the local high school if she were mainstreamed? Of course not!

         Please reconsider this policy of full inclusion. It does not work for all.

         Naja Frelich, CI/CT
         Parent, Child and Advocate

       • I agree with you, Janet!

         • Agreed!

311. As a mother of a preschooler with Down Syndrome I strongly support this policy. My son was only offered 4 days of special ed segregated preschool (to preload language and academics for kindergarten – so he could then be included) and 2 days in a Head-Start program. While the Head-Start Program would have been inclusive, it also would have not been a “natural environment” due to the composition of the class room. At this point there are no early childhood classrooms in our school district that provide a natural (typical average composition) environment. We decided to send our son to our neighborhood preschool, which he is attending in his second year and get his therapies from the school district therapists in their therapies rooms outside of school hours. Being in an inclusive environment has been wonderful for our son. He learns a lot by watching peers and imitating them. This year he has made huge leaps in his language and many expressions clearly come from his peers. He is well adjusted and follows classroom rules. He has a friend he has playdates with and he is invited to birthday parties. Not only has he learned from his peers, his peers have learned from him, that being different is ok.
     I am hopeful that this policy will help more young children being included with kids without disabilities. I am agreeing with the NDSS that the ratio of children with disabilities to children without should reflect the natural proportion (10 – 12%), as well as data collection should reflect that my husband and I are paying for our sons inclusive experience and not the school district.

312. As an organization that supports families of young children with disabilities seeking inclusive early childhood services in our role as New Jersey’s Parent Training and Information Center, as well as our role assisting early childhood programs such as child care centers, family child care providers, and Head Start, to effectively include young children with disabilities in typical settings, the Statewide Parent Advocacy Network (SPAN) strongly supports the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education, and commend the Departments for their collaboration and excellent policy statement.

     Inclusive early childhood experiences are critical for the development of young children with disabilities and help set the stage to inclusion in kindergarten through high school as well as an inclusive life in the community as an adult. On the other hand, segregating young children with disabilities, as our state far too often does, usually leads to a life of segregation including sheltered workshops and institutions or sitting at home with no future or meaningful lives.

     SPAN strongly believes that the joint policy statement clearly identifies the scientific and legal foundations for early inclusion, identifies the barriers, and recommends specific, common sense strategies for partnering to “build a nationwide culture of inclusion”. The emphasis on applying the policy “to all young children with disabilities, from those with the mildest disabilities, to those with the most significant disabilities.” is particularly important, as children with significant disabilities are often the ones denied inclusive opportunities.

     The policy calls for state policies to “ensure that the principle of natural proportions guides the design of inclusive early childhood programs,” and adds in a footnote the statement that “natural proportions” means the inclusion of children with disabilities in proportion to their presence in the general population. (This is consistent with the Third Circuit Court of Appeals dicta language in a case where a district sought to have a young child with disabilities in a class that was 50% children with disabilities and 50% children at risk; the Court of Appeals indicated that this was not the “least restrictive” environment for a young child with disabilities and specifically mentioned the concept of natural proportions).

     In order to implement this policy statement, SPAN believes that it will be important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring.

     Currently an early childhood setting is counted as a regular early childhood program (inclusive) if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”. At this time, if parents are unable to convince the school district to place their child in an inclusive early childhood setting, and pay themselves for their child to attend an inclusive program, the district is still given “credit” in the OSEP 618 Preschool Data Collection for the child attending an early childhood setting in an inclusive (regular education early childhood) program. This is patently unfair and needs to be changed.

     Given the real life experiences of families “on the ground,” which we hear about every day, we also strongly support efforts to ensure a smooth transition from early intervention services in natural environments to inclusive preschool services. We also note that there must be proactive disciplinary techniques using positive behavioral interventions and supports (we are very active in working to bring the Pyramid model to NJ as part of the Early Childhood Learning Challenge grant in our state), and prohibition of expulsion or suspension of young children, especially given the gross racial disparities in discipline on the basis of race. Finally, we urge that data be collected on traditionally underserved populations based on specific disability, race/ethnicity, etc. to ensure that children of all races/ethnicities have equal access to inclusive settings without fear of biased disciplinary action.

     Since our inception as a family advocacy organization over 25 years ago, SPAN has strongly supported early childhood inclusion, and are pleased to see the progress made in this field. Again, we commend HHS and ED on this important joint policy statement which will help us in our work in New Jersey with families, school districts, and typical early childhood programs. We also note that our state early intervention and preschool special education systems are working with stakeholders, including our Map to Inclusive Child Care Team among others, to develop Guidance on Providing Services Within the Routines in an Inclusive Early Childhood Setting that will include Expectations and Benefits of Inclusion/Practice Strategies, Step by Step Process for Partners to Use, and Resources, which will help families and professionals in the EI. preschool special education, and early childhood communities work together to increase and enhance early childhood inclusion in our state.

313. o The policy statement provides clarity and a stronger framework to conceptualize high quality inclusion than do the NE/LRE statements within the laws alone. Key points include:
     • The term “culture of inclusion” illustrates the complex nature of how embedded practices around inclusion are in value and belief systems of not only individuals and programs but our communities and nation at large. The early childhood community has an opportunity and even obligation to serve as the foundation of meaningful inclusion experiences for young children.
     • All early childhood programs’ culture of inclusion starts with ensuring that the expectations and goals of children with disabilities are always considered with those of other children by implementing the principles of access, participation, and support (as defined by DEC/NAEYC).
     • The concrete recommendations of action at all levels, provide many opportunities to consider and further exemplifies the complex nature and multiple entry points to begin to affect change and improve outcomes. Some examples are things that can be implemented fairly quickly and others will undoubtedly take a great deal of time and effort to shift.
     • The scientific and legal foundations citations are excellent to inform policy makers and justify the need for a shift in culture and practice. However, attitudes and beliefs will likely not be swayed by the citations alone. Policy will need to change to inform the practice and the success of the practice will then start changing beliefs. At the same time, professional development programs need to reflect the culture of inclusion so practitioners, educators, administrators, and families are open to new policies and practices.
     • Funding is always an issue so having preliminary data that shows quality inclusion is not more expensive than segregated service delivery models is good leverage. The recommendation to braid funds and allocate resources differently is important. The list of questions provided is thought provoking and are good considerations in those discussions.
     • Enhancing professional development at all levels, across all early childhood settings is paramount. The policy statement gives specific strategies and considerations to build highly qualified staff with a strong understanding of universal design, competencies and positive attitudes in order to foster the development of all children. This will lead to families having an increase in choices of meaningful inclusive experiences and willingness to access inclusive setting for children with disabilities.
     • Appendices provide very useful information as well as links to tools and models for implementation of high quality inclusion in early childhood settings.
     o In general, the policy statement provides much needed guidance around high quality inclusion within early childhood settings. It acknowledges the very real challenges and also gives very specific, feasible recommendations for actions to help transform to a culture of inclusion.

314. As a long-timer – since 1975 – in the field of early childhood special education since IDEA’s original implementation via working at Head Starts in Massachusetts, Connecticut, New Jersey & New York, as well as at a few of the original HCEEP projects, and now at at my federally-funded PTIC & state-funded special education parent centers — I certainly welcome this “draft Policy Statement on Inclusion of Children w. Disabilities”. I truly believe this joint statement between DHHS & the ED is very welcome, maybe a bit late, but none-the-less critical at this time, as the feds try to advance their PreK agenda and other initiatives for the Birth to Five populations.

     It is a great, positive step in the right direction, especially as many states, most thru their Early Childhood Advisory Councils (established after the 2007 Head Start Act reauthorization) or similiar, brought together many professionals working with all children birth to five (or a little older) from all state government agencies, many service providers, professional development programs, and various other disciplines, to try to improve services and increase opportunities for children of all abilities, and access for their families.

     My own state has tried to demonstrate great leadership here — and there are many fine initiatives supporting better integration / inclusion of young children w. disabilities in many types of early childhood settings — both general & special — but we remain challenged at the local level with actual implementation. We are well-intended, but many families of young children still struggle to navigate both the early intervention / preschool special education service systems while trying to enroll their children in infant, toddler & preschool programs in both the private & public sector.
     We are rich w. services & resources, but still not completely coordinated in how to make access stress-free for families, who may be dealing w. far more than just their young child w. a disability.

     And most importantly, as many other commenters have already noted, is the need for better enforcement of the long-standing, already-existing laws, regulations & requirements to provide services to young children in the most natural environments, least restrictive settings, with the most developmentally & individually appropriate approaches. Even this week,
     I still have had to remind child care centers, after school programs, day camps, Head Start programs, and even some ECSE preschools about their responsibility to not discriminate against children w. disabilities because of IDEA, or the ADA, or Section 504 of the Rehabilitation Act. I am continually coaching the families of young children w. disabilities trying to access any EC program with their IFSP or IEP — about how to get their child “in” & how to make sure the services authorized are actually provided.

     So while I am looking forward to a final version of this policy statement, I am also looking forward to some assurances that states & counties & municipalities, as well as the broader Birth to Five communities will make what we already have work better, and develop some new & positive approaches for the children yet to come.

315. Thank you for this opportunity to provide feedback. We have come a long ways since the 30s and early 40s when my brother, who had cerebral palsy, and others, did not have access to public education. I also remember being asked not to go to restaurants if my brother was with me. Inclusion and equal access are noble goals. Having said that, I believe it is important to honor Sec. 300.115 in IDEA, which describes offering a “Continuum of alternative placements”.

     The book “Evidence-Based Interventions for Students with Learning and Behavioral Challenges” (2008), edited by Morris and Mather, has this on page 371 in the section related to “Place” in the chapter related “Effective Service Delivery Models”:

     “The lack of clear, positive outcomes for students with learning and behavioral difficulties in particular placements has led researchers to conclude that no one place can fit the needs of all students. Indeed, after reviewing the outcomes of research on inclusionary practices, Hocutt (1996), Manset and Semmel (1997), Waldron and McLeskey (1998), Murawski and Swanson (2001), and Zigmond and Magiera (2001) all concluded that not all students with learning or behavioral difficulties can benefit from receiving educational services in one type of placement. Instead, as Zigmond (2003) noted in her summary of three decades of research investigating the efficacy of the various educational placements in which students with disabilities received their special services, “what goes on in a place, not the location itself, is what makes a difference.”

316. D/HH children often are disabled simply by the society in which they live, a society that values spoken language. Thus, being educated in an environment with a critical mass of 50+ peers in which both ASL and English are valued as the languages of instruction, D/HH children do not experience so much of the disabling qualities of this society. The inclusion illusion is that many D/HH children can succeed in their neighborhood schools, who are ill-equipped to serve them. For most D/HH children, inclusion is actually seclusion, even with the best interpreting services. I say stop the madness in the mainstream specifically for D/HH kids. They deserve the choice of placement which fits their individual needs, not a mandate from the government.

317. I am the mother of an autistic son and two typical developing daughters. My son has had the opportunity to take part in a high quality inclusion preschool offered through our local ISD. The teachers and professionals that we have worked with have been vital in the progress that my son has made. He has spent two years in the program and is now caught up to an average-low average skill level in every area including speech, self care and motor skills. When we began the program he wouldn’t even say or respond to his name. Having him alongside his typical peers, has allowed him to make GIANT STEPS in his development!!!

     Our local ISD has informed us recently that the three year old inclusion program will not be offered next school year. I have been protesting this decision for months because our County’s inclusion model is phenomenal and we should be leading the way for others to follow!!! Early Intervention is crucial to helping children disabled or delayed to develop meaningful skills. Self contained classrooms do not promote the skills (especially for autistic children), in particular social skills that inclusive classrooms provide. I am grateful that my ISD had the inclusion classroom to offer my child and he was not pushed into a self contained class.

     Having my daughters grow up with an autistic brother has made them face challenges that many other children have not had to be exposed to, but they are the most loving, caring, thoughtful and generous kids. They are the first to welcome the new kid and play with the other special needs children in their classes. They accept everyone and embrace their unique characteristics because of their exposure to their brother. They understand that he is different, but they also think he is one of the coolest kids they know.

     Inclusion is not only helping children with special needs in innumerable ways, but we are creating a culture in which all children can learn to embrace differences and accept others.

318. As a mother, attorney and special education advocate, it is refreshing to see such a strong Federal policy statement drafted for inclusive education. But it’s 40 YEARS since IDEA clearly set forth each student should be first placed in the Least Restrictive Environment with appropriate supports and services to now result in such a policy statement. That said, let’s do this!

     Our son is headed to high school next year, the first student with Down syndrome in our District to enter on diploma track. It will be a new experience for all. Across the country by third grade, students are removed from “diploma track” so that their standardized testing results do not impact the star-rated schools, and off the children with IEP’s go to resource rooms, districts other than their home district and some just leave to homeschool to avoid the inclusion battle. While inclusion has been difficult to continue through elementary and middle school, we worked with our district for the important supports and services needed for an inclusive environment to work for all. It has not been an easy road, but our voices have been heard. Maybe a strong policy pro-inclusion for early childhood would assist with this sad situation.

     As has been mentioned, there does need to be a natural percentage of students with disabilities in early childhood inclusive education. Also, throughout the school years, appropriate supports and services must be available to the student. Appropriate accommodations and modifications must be provided for success, which means more training of quality teachers in UDL and paraprofessional support. More funding, or appropriate oversight and use of current funding, must follow. Let’s give the IDEA Full Funding Act some traction please.

     Thank you for this policy as it will hopefully positively impact secondary, postsecondary, and employment for those with disabilities.

319. I have been a practicing speech/language pathologist for the past 40 years. In that time, I have serviced many children presenting with a variety of special needs. Placement decisions have always been based on the IEP/IFSP team’s best assessment of where the child’s needs fall with the continuum of services. There is no one fits all path to helping a child reach his/her full potential. The ultimate goal of every individual educational program is to allow a student to function in the least restrictive environment. For many of the children, it is a slow journey. Mandating integrated programs for every special needs child, before they are ready, would not only shortchange the identified children, but would disrupt the educational experience of their typically developing peers. I urge the Department of Education to rethink this proposal and come up with a plan that would consider the needs of all of our children.

     • As it was explained to me some time ago, goals for occupational therapy are somewhat determinant by hearing impaired team members. I have a belief about my student and their ability.

       Naturally language is learned. Speech then relies on an ability to vocalize and then to gather feedback from the sound. With your years of experience it seems you would have contributed to the robust body of literature referenced in the draft in some way. Thank you.

       With your experience, please consider contributing again by commenting on what the Departments of Education and Health and Human Services can do that would better recognize the challenges you mention.
       Thank you.

320. I am very concerned that the scope of the policy statement exceeds the US DOE’s authority by attempting to establish mandates which are beyond existing IDEA statutes and regulations. The current IDEA statute and regulations establish the correct focus on individualized education based on meeting the unique needs of each child in the least restrictive setting appropriate. IDEA also requires each state to provide a continuum of services, including inclusive and specialized settings, to meet the needs of all students with special needs. In so doing, IDEA establishes the right of children with special needs to a range of educational settings of programs. The policy statement should be amended to include language that affirms these statutory requirements of IDEA.

     • My reaction to reading the draft puts me out on a limb with your comment, Jim. I interpreted the draft to celebrate the work of others and to reflect a desire for better outcomes in a policy statement. Apart from any argument about what is or is not a challenging about the attitudes of others.

       I was slightly concerned for how the draft presents Early Childhood System Recommendations. Then I realized my attitude about how peers benefit and suddenly reordering item 5 would seem to demonstrate how vital the start is.

321. The data that we see reported when children are attending a center program with same their same age piers, suggest that the child makes excellent progress towards their individual goals. The children have an opportunity to be in a diverse learning environment which supports engagement, attention and play. Teachers and therapist are able to share resources in group settings and promote activities to support a child’s growth and behavior.

322. I full support this policy, and hope that it extends to inclusion for students with disabilities at all levels of education, from Pre-K through college. Parents should not have to fight for the child’s right to attend school with their “typical” peers. The default position at all schools for all children should be inclusion. When schools are not built on a foundation of inclusion and universal design for educational access to all it is too easy for administrators, educators and state officials to side line children because of their disabilities, or because their progress does not match their peers or they are not advancing by the same milestones. We wish our son had access to an inclusive setting for Pre-K; he did attend a wonderful special education preschool but to shut a student out of experiences with his typical peers (and to make that decision when the child is 2-3 years old) makes no educational, developmental, or social sense. Even in nursery, he was kept in the baby room because he didn’t meet the milestones for advancement (walking and toilet) even though for cognitive and social development he should have been kept with his peers — he was the only child with a documented disability, and the nursery was welcoming but too often our children are “included” as tokens but there is not building from the ground up for inclusion to take place, across the board, in all geographic locations, and within all schools, in a way that is mindful, developmentally appropriate, and truly inclusive in the design of access, curriculum, and peer-to-peer modeling. Children with disabilities should not be segregated; instead our institutions of learning should build on a foundation of inclusion and this policy statement is an important next step.

323. As the Executive Director of the Down Syndrome Guild of Greater Kansas City I serve over 1300 families in 37 counties in KS and MO. Our organization wholeheartedly endorses these recommendations as Research proves that inclusive education brings strong benefits to the entire community and educating students with disabilities with their non-disabled peers is a win-win for everyone.

     We need stronger policies in place to promote inclusion as there is no “special education world” waiting for students with disabilities. Just one world where everyone needs to know how to interact and co-exist. Early childhood inclusion sets the stage for success in later years. The more exposure students with disabilities have to their non-disabled peers, the more capable they are likely to be.

324. YES! We have years of research showing the effectiveness and positive outcomes of inclusion. I have a 10 year old with Down syndrome. The school we attend did not offer inclusion at the preschool or pre-K level. Our only option was a self-contained classroom. We chose to enroll her in a community program in addition to the school program so that she would reap some benefits of being included with typical peers. We now fight the good fight for inclusion in the elementary school yearly. Progress is slow, it shouldn’t be. My daughter spent Kindergarten through 3rd grade at her home school with inclusion In the general education classroom 57% of the day. She has built friendships and community. Now, due to Administration deciding to move the “moderate” program to a different school site she is being forced to go to a new school while her friends remain at her home school. All the years of building those friendships and community are now being taken from her. Schools need a clear definition of what inclusion is. It is imperative that inclusion begin at the early childhood level and continue through the years. I would love to see this inclusion statement continued to include the elementary years, middle school years and the high school years.

325. I strongly support this draft statement (along with the two requests for changes brought up by the NDSS). Inclusion doesn’t mean accommodation. It doesn’t mean shoving a square peg in a round hole and then patting yourself on the back about it. Inclusion is about creating a world that truly respects and honors every individual – across the whole life span. My daughter who has Down syndrome attends the same fantastic preschool that her older typically developing brother attended. She is the first kid with Ds to be a student there, but there was never a question about “including” her. She has a right to attend any school, to be part of her community, to learn and grow, to contribute and to have friends. I support inclusion not because it will contribute to my daughter’s development, or provide her with peer models, or foster deeper understanding among people without disabilities (though all of those things are true). I support inclusion because we are ALL BORN IN. Segregation cannot be defended. If the school environments we are creating don’t work for all kids then they don’t work for any kids.

326. The Council of Parent Attorneys and Advocates (COPAA) strongly supports the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education, Office of Special Education (OSEP) and commend the Departments on their collaboration and commitment to high expectations and high quality for preschool children with disabilities.

     Research demonstrates that inclusive early childhood experiences open the doors to lifelong learning, interactions, and achievements. We whole heartedly agree that quality education for inclusive lives begins in early childhood and continues throughout a child’s life experiences into schools, places of employment, and the broader community.

     The joint policy statement clearly identifies the scientific and legal foundations for early inclusion, identifies the barriers, and recommends specific, common sense strategies for partnering to “build a nationwide culture of inclusion.” The emphasis on applying the policy “to all young children with disabilities, from those with the mildest disabilities, to those with the most significant disabilities.” is particularly important, as children with significant disabilities are often the ones denied inclusive opportunities. It is indeed well documented that the beginning years of all children’s lives are critical for building the early foundations of learning and wellness needed for success in school and later in life. Like all children, children with disabilities must be exposed to a variety of rich experiences where they can learn in the context of play and everyday interactions and engage with their peers with and without disabilities.

     It is also well documented, over the last twenty-five years, that studies investigating the effects of placement in general education classrooms reveal positive outcomes in the areas of the quality of the Individualized Education Program (IEP), time of engagement, and individualized supports. Significant increases in IEP quality on measures of age-appropriateness, functionality, and generalization were found when students moved into general education classes from special education settings even though the special educator remained the same (Hunt & Farron-Davis, 1992) . Within the general education classroom, there was an increase in the amount of instruction on functional activities as well as basic academic skills such as literacy for students with severe disabilities (Hunt, Farron-Davis, Beckstead, Curtis, & Goetz, 1994) . In addition, students were observed to be less engaged and often more alone in self-contained or segregated classrooms.

     Positive educational outcomes are not limited to academics. The National
     Longitudinal Transition Study examined the outcomes of 11,000 students with a range of disabilities and found that more time spent in a general education classroom was positively correlated with:
     a) fewer absences from school,
     b) fewer referrals for disruptive behavior, and
     c) better outcomes after high school in the areas of employment and independent living. (Wagner, Newman, Cameto, & Levine, 2006) .

     The evidence base clearly shows the benefits of learning alongside one’s peers without disabilities. The proposed policy is in complete alignment with best practice and with Congressional intent in passing the Least Restrictive Environment provision in the Individuals with Disabilities Education Act (IDEA). IDEA requires that that the first consideration and priority be given to provision of the full range of supplementary aids and services that might aid in implementing the student’s individualized education program in the least restrictive of all educational settings – the regular education classroom in the neighborhood school.

     The proposed policy calls for state policies to “Ensure that the principle of natural proportions guide the design of inclusive early childhood programs.” Then in a footnote says “natural proportions” means the inclusion of children with disabilities in proportion to their presence in the general population. This is an important component in determining if a placement is in fact inclusive; however, we believe a 50% threshold [as supported/proposed in the policy] to be far too high as this percentage is not supported by research and best practice.
     Therefore, in order to implement the new policy statement, it will be important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring. They are:

     • Currently, an early childhood setting is counted as a regular early childhood program (inclusive) if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (no greater than 15%) is considered “a regular early childhood program”.

     • At this time, if parents are unable to convince the school district to place their child in an inclusive early childhood setting, and pay themselves for their child to attend an inclusive program, the district is still given “credit” in the OSEP 618 Preschool Data Collection for the child attending an early childhood setting in an inclusive (regular education early childhood) program. This is patently unfair and needs to be changed.

     COPAA appreciates the opportunity to comment and would be happy to answer any questions and/or discuss our recommendations further.

     Sincerely,

     Denise Marshall
     Executive Director

327. This policy that defines “inclusion” in early childhood programs as “including children with disabilities in early childhood programs together with their peers without disabilities,” eliminates the consideration of Least Restrictive Environment (LRE). For example, often deaf and hard of hearing students that are placed with non-disabled peers don’t receive a free appropriate public education because the school does not have the qualified staff to implement the Individual Education Plan. The reason for LRE is that the placement of disabled students with non-disabled peers can more restricting than the placement at a specialized school such as a school for the deaf. If we want to allow the consideration of LRE, then this policy should not go into effect.

328. As a mother of a child with Down syndrome, I highly support this policy statement put forth by The U.S. Department of Education and the U.S. Department of Health and Human Services. It is common sense to provide all children with the same opportunities in high-quality early learning. Not only are there laws written specifically for this, but there are countless studies showing how inclusive learning is best for everyone. This shouldn’t even be up for discussion.

329. My nearly three year old daughter with Down syndrome has been included in a general education day care/preschool early learning environment since she was seven months old. She is excelling. Her receptive speech has tested in the typical range for all children, and while she has expressive speech delays, being around other children who are verbal and interacting with her has clearly made a huge difference. In fact, all of her early intervention therapists have praised the progress she’s made in her inclusive environment. Also, all the other kids love her; they run to greet her when we drop her off in the morning and are excited to see her when we meet them by chance in a grocery store or at the park. These are children who will be her classmates in school and her peers through life; I am so glad that they are getting to know her early and developing bonds now, before prejudices set in.

330. Inclusion is a civil rights issue. Every pre school, kindergarten, elementary, middle and high school aged child has a civil right to be fully included with their age appropriate peers. If children are not fully included in schools then they will never be fully included or accepted as adults.
     When you see, meet or think about a person with a disability you must presume competence or competence will not be achieved.
     My daughter will be entering first grade next year. She has Down syndrome. She is fully included in school and life. She always has been and always will be.
     Because of the modeling of her peers, her own tenacity and mine she is a thriving six year old living a pretty typical six year old life.
     All children deserve this.

331. I’m very supportive of these recommendations, based on my daughter’s experience of an inclusive early childhood education. Inclusion was very good for her, and, I believe, all the kids in her class. While there will be specific cases where it is not appropriate, it should definitely be the default standard. One of the things I noticed is how inclusion created an expanded sense of ‘normal’ for these kids that they will take with them their whole lives. For the children in her class, my daughter was not someone wholly different or strange to be feared and avoided – she was just a kid with a few differences. In the future, when they see another child with a disability, they stand a much better chance of seeing the person and not the disability. This is such a contrast to how I experienced school years ago, where the kids with disabilities were kept apart. The rare occasions when I encountered them, they seemed so different and I didn’t know how to relate. Inclusion at the early childhood stage when kids are developing their social sensibilities will help make inclusion more successful at later educational stages.

     I would also particularly echo the need for professional development for teachers – this should also include adequate pay. Early childhood is one of the most crucial times in a person’s life in terms of intervention, and yet early learning professionals are some of the most undervalued and underpaid people around.

332. As an Administrator of Special Education I am commenting in support of the Draft Policy Statement on Inclusion of Children with Disabilities. The meaningful inclusion of students with disabilities is a practice that is strongly supported by both the law and the research. There are a variety of barriers to inclusion but one of the largest barriers I see in MIchigan is that there are a limited number of preschool opportunities available at no cost to families in our state. Any national policy on inclusion of students with disabilities should take into consideration that availability of general education preschool programming will differ greatly from state to state. According to the 2014 Annual Report published by the National Institute for Early Education Research only 26% of Michigan’s 4 year olds are enrolled in preschool in comparison to Florida that had 80% enrollment. Greater access to free preschool programming state-wide would greatly increase our access and availability to inclusive programming opportunities for our students with disabilities.

333. Family Voices NJ at the Statewide Parent Advocacy Network strongly supports this statement. There must be a smooth transition from early intervention natural environments to preschool inclusion. LEAs must offer a continuum of placement options, not mostly “preschool disabled” classes. There must be proactive disciplinary techniques using PBIS and no expulsion/suspension of young children. Data should be collected on traditionally underserved populations based on specific disability, race/ethnicity, placement and remedies applied to enhance what the natural proportions should be for that population. As parents and advocates, we strongly support this policy statement.

334. Having working in the field in the Pk-12 venue for over 30 years, the value of inclusive setting can not be underestimated in their benefit for ALL children in schools.
     The major draw back to good inclusive setting is a supportive and knowledgeable administrators on a building and central office level. The lack of understanding limits the support need to truly make an inclusive setting be a positive setting.

335. I am an early interventionist (Occupational Therapist) who has been serving children & families with special needs for over 12 years. I know that most of you reading this will not find this a startling discovery…but finding childcare setting who provide healthy environments and interactions with children in general is difficulty to find. So, when I read the Challenges to Inclusion (p.5) of the Draft: Attitudes & Beliefs, I am immediately struck by the notion that they feel it is a “feasibility” problem, fear of the unfamiliar and resistance to change when in actuality when you have candid discussions with caregivers in these setting, it comes down to limitations with the system…no training, no support, and lack of funding. Class sizes that are too cumbersome for 1 person to manage. So, is it attitude, well Heck Yes! Attitude that a federal/state entity would propose to mandate inclusion (which is a GREAT idea and both from a research and legal standpoint) but with known and foreseen limitations in funding, staff quality, and knowledge.
     Let me drive this a little further… early childcare teachers are not paid well, from what I have seen in my years are that the good ones decidedly move on to other jobs where they can make more money, and the daycare owner who has just spent valuable time and money training someone is left to hire yet another person non-experienced to fill that position. A vicious cycle. There is an old adage, “You get what you pay for.” There is no doubt this will continually fester as a problem until we make an investment in our children.
     Driving even further….Has anyone seen the average daycare setting’s toys/activities (especially in rural areas in poor communities). Often there is just the shell of a toy, I mean a shape sorter without shapes, cause & effect toys without batteries, the list is long. I am hard pressed to believe that a childcare setting will be capable of purchasing a specialty swing so that the child with special needs can be included in outdoor activities. Talk about barriers….put any child in a setting where they have no “meaningful” toys/activities, give them a teacher that is “not” connected, and then introduce a child with social/emotional and behavior issues into this setting and we are set up for disaster. At what point does the State who inspects these settings even look at what children are doing during the day. Do State Inspectors even have Early Childhood backgrounds and experience? What are they inspecting?
     I purposefully maintain a presence in a child’s classroom when I visit facilities because I think it is critical to model interaction and activities for the teacher. I believe in the importance that all children, even children with special needs need to be in healthy and stimulating social environments with their peers. I truly want all children to experience the fullness of wonderful relationships, an early introduction to learning opportunities, and that parents experience the peace of mind that their child will be cared for and loved in the childcare setting. However, I struggle with how things look NOW without full inclusion and wonder if there is sufficient commitment to what is proposed in the draft.

336. As a behavioral health professional and a parent to a child with delays, I fully support and advocate for this policy of inclusion. It is not only good for the child with special needs but for all students. It builds healthy character qualities in community members including tolerance and compassion. Our communities need this more than ever now.
     I understand that teachers and staff will need training for this to work well. It is certainly worth the effort. The positive impact on society is immense.

337. Yes I believe in this with my entire heart. Kids learn first from other kids. Segregating kids at the begging creates a huge problem for typical children and kids with different abilities, how can you expect a kid to start kindergarten without “negative learned behavior” and you want them to learn “appropriate socialization and behavior skills” then that is what you have to have them exposed to with their typical peers. Especially at preschool age… They are there to just learn how to be kids And make friends and segregation does the direct opposite. It leaves a negative impact on both the typical child and the differently abled child. I had to spend the last three summers trying to reintroduce children to Aydin in an inclusive setting like park, fountains and beach and concerts because she would become traumatized and terrified of kids after her years at Easton. Also another important things to understand r

338. http://azisamazing.blogspot.com/2014/04/the-solution-is-inculsion.html

339. To become a successfully contributing citizen in our American society, a person needs to have good communication skills and a strong educational background. In order for children to have these critical skills, and be ready for careers of their choosing, they must have an education that supports a healthy and positive development of cognitive, linguistic, social and emotional skills. The current concept of inclusion does not support a healthy and positive development for deaf and hard of hearing (DHH) children. While the idea of “inclusion” across the spectrum is well-meaning, it in fact has been detrimental to most DHH children.

     First and foremost, DHH children need access to a language that is fully accessible for them. Children need language to learn world knowledge, develop executive functioning skills and develop a sense of their own identity. For many DHH children, the language that is fully accessible for them is American Sign Language. DHH children need to be with their peers and Deaf adult role models. Research tells us that language is a social activity. Peers learn the fastest and the best from each other in the area of language. Deaf children need a critical mass of peers to learn language skills such as idioms, puns and social language in addition to academic language.

     As Deaf adults ourselves, we have had first-hand experiences attending our neighborhood schools and we have walked in the very same shoes of being a deaf child in a classroom with hearing peers. Inclusion for children who are hearing has a very different meaning for children who are Deaf. We do not have the same kind of access to language and social interaction as those who can hear and learn through incidental or implicit conversations. We often do not have access to staff and peers who understand our communication needs and who can communicate freely and fluently with us.

     As long-time educators who have worked with DHH children for more than 15 years, we see far too many children come to our state school for the deaf lagging years behind their hearing peers academically because they attended neighborhood schools that did not understand their unique language needs nor have the resources to support their education. Their schools and families thought that their child was being “included” but did not realize that their sons and daughters were in fact, not thriving. We have growing amounts of evidence that directly links students’ social and academic language skills with academic growth. Students with severe language delays and/or language deprivation are not able to participate meaningfully in state-mandated curriculum and assessments. These students are stunted before they even start their academic careers and must hurdle huge barriers in order to become a productive citizen in their adult lives. The concept of inclusion really means “exclusion” for them. Please do not issue further policies that will hurt deaf children.

340. This policy statement on the inclusion of children with disabilities in early childhood programs, written in drafted form, not only focuses on the critical advances of inclusion, but it clarifies the dire necessity of offering a high quality inclusive early childhood environment that delivers best practices for those students with IEP’s.

341. Inclusion in early childhood education programs is critical to the development of young children with disabilities. We have been lucky in that our daughter (born with Spina Bifida, gross & fine motor delays as well as some medical interventions needed) has been able to attend a mainstream daycare from the time she was 6 months old. At 3 years, she transferred to our local preschool in a class that is 50% typically developing children and 50% children with some sort of developmental delay. Being around other children of varying abilities (from fully typical to significantly delayed) has strongly driven her social and behavioral development in a positive way. It has also exposed other children at a young age to a friend with visible physical disabilities, teaching them that in some ways they may be different, but that in many ways they are the same.

342. I support both Depts for joining together for this philosophical statement. It seems intuitive that all children should be included in their neighborhood schools, in proportion to the general population (not a made up artificial number to satisfy some statistic). Preschool children (as well as older students) live in inclusive environments with their family and in their neighborhood. They go the grocery store, the mall, restaurants, amusement parks, etc. with their friends and families. That is also inclusive. Children (and adults) with DS (or other disabilities) are already included in the community, so it makes sense that they should be included in education from the beginning. The expectation today is that they will live and work in the community as adults, many will go on to post secondary education or job training, so why shouldn’t they be educated in the community as well, starting with pre-school, just like their siblings and neighborhood friends do? We educate all of our children so they can grow up to be as self-sufficient as possible, as adults. Children with DS (or other disabilities) should be afforded the same opportunity for the same reason. And this starts with pre-school. I am a strong and opinionated advocate for all people with disabilities, and believe they should be fully included. I have a teenager with DS in addition to autism and other chronic health issues. I have worked as a physical therapist for 26 years, so I see “disability” in many forms at many ages. We are not allowed to discriminate or segregate based on a persons ethnic origin or skin color (things they were born with and did not chose), so why is it still acceptable to discriminate and segregate those with different abilities that they were born with, or acquired, that they did not chose? Thank you for opening the doors a little more for those who should be included just like everyone else. Children with DS have less opportunity for employment as adults if they do not have an inclusive education. It isn’t just about teaching children who have DS or other disabilities how to live in the community, IT IS ALSO TEACHING THE REST OF THE COMMUNITY HOW TO LIVE WITH, INCLUDE, AND RESPECT THOSE WITH ‘DIFFERENT’ ABILITIES.

343. I believe IDEA already sets forth that children should be taught in the mainstream classroom as much as possible, and I fully agree with this new policy statement. In addition IDEA states that LEA’s are required to provide appropriate services to support these children in their educational environment. Inclusive Education has been shown to improve outcomes for all students, provided LEA’s are following the law in regard to services. My son is an excellent example of inclusive education working well, yet my district continues to try and move other children out of the mainstream classrooms into secluded classrooms against the wishes of the parents.

     Thank you for making this policy statement, I can only hope that the states and LEA’s will heed it!

344. Thank for this initiative. I have a disability and because I was included in an inclusion preschool class I was able to go on. It is sad that this country still has a system that allows segregation. My advise is that The Feds asks states to create a transition inclusion plan for the children who are segregated, specially those who are at special schools . We need to close the gap of separation. Ask states reduce the number of segregation to a certain percent every year. They need to come up with a plan of action.
     Create a website that compare estates plan of action and track the outcomes to close the gap of separation

     Thank you

345. I applaud this nationwide effort to promote the value of inclusion for children with disabilities in high quality preschool programs. My son with Down syndrome participated in two different preschool programs, one an exceptional children’s program run through the county, led by a very highly qualified special education teacher. In this class of about 10 children, he had two typically developing children. He benefited a great deal from this program and learned an incredible amount of information in a short time; he would have benefited even more, especially in terms of speech, had there been even more nondisabled children in his class. However, the quality and experience of the teacher was key for my son, and I would emphasize this in putting together any program for children with disabilities. He also attended an inclusive private preschool, taught by a less-experienced teacher, who was nonetheless excellent for him. She built up his confidence tremendously and the rest of his learning I attribute to his 19 nondisabled peers. Thank you.

346. Editing

     the 4th bullet “Meaningful inclusion in high-quality early childhood programs can support children with disabilities in reaching their full potential resulting in societal benefits more broadly ” is not clearly written. The end of the statement should read, “resulting in broad societal benefits”

     In the next sentence the comma after “programs” should be eliminated.

347. I forgot to add a comment about Mental Health. My son was nervous last year about starting high school and he was talking about dropping out. Our neurodevelopmental pediatrician said to try counseling, but that it might not help his motivational issue or self help issues.

     We went to outpatient counseling and the therapist saw him 3 times and said she can’t work with him. All he says is that he is bored, wants to go home and play video games. That’s why we are here.

     She said that she could not apply her skills of cognitive therapy to a child with developmental delay. She suggested behavioral therapy for children with autism and the listing is in the high risk group.

     I didn’t know what the acronyms for the mental health therapy that was listed in the draft. But, I sure hope there is a new approach to mental health for kids with developmental delay to work on whatever issues arise.

348. I think the IEP/IFSP plan should be individualized. My son did well in a self-contained restrictive environment for learning purposes. The amount of repetition for him to learn and retain in memory is excessive and far more exceeds what teaching methods could be done in an inclusive environment. A small class size of 12 with a teacher,assistant and an aide was the support that he needed. Especially, if he received a different reading instruction like the Wilson reading program. There would be no way to implement a different reading program in a regular classroom. In addition, he had selective mutism which is a social communication anxiety disorder. He progressed well in small group sizes.

     He is in 9th grade and failing the inclusive classes for Health and graduation requirements. He is doing better in the resource rooms. I have the teachers riding on me when he is placed in a regular classroom about why my son…… I agree he should be in a resource room class and not left for the teacher to struggle with 25 other kids in the class and spend more than enough time trying to teach my son and get him to pass and/or retake a test.

     My concern is that next year he will be taking drivers education. It is a fast paced regular classroom. My son’s reading level is about 4th grade instructional and 3rd grade level for independent reading. There are no modifications to the drivers test. There is very little support given to him for next year to help him to learn it and pass it. The Child Study Team just says “Most of these kids don’t pass it the first time. There is nothing we can do about it”.

     Keep in mind that while we revise laws to include children with disabilities into an inclusive class, we are maintaining a standard of education and the child really is progressing. And the other option of a self contained class should be left open for discussion with the Child Study Team and the family as a choice also.

349. The policy statement addresses the concerns expressed by other comments. The definition of inclusion includes proper supports, best practices, and individualized accommodations. It addresses the need to support inclusion with adequate funding. It does not recommend placing a child in a setting that does not provide the education that the child needs.

     The statement appears to be thorough and and reasonable in its aims and its awareness of the challenges that need to be addressed.

350. I commend the Department of Education’s position “that all young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations.”

     Young children with disabilities and their families should have access to high-quality early childhood classrooms wherever typically developing peers attend – family child care, Head Start, private preschool, public pre-K, parochial school, or charter school. However entrance to the program, or being there, is not enough. I suggest three priorities:
     1) Supports (SLP, OT, PT, paraprofessional, feeding therapy, AAC/AT, transportation) MUST follow the child and family to whatever early childhood program they attend, as mandated in their IEP. This could mean increasing itinerant services.
     2) Professional development about inclusion and strategies to support young children with disabilities MUST be provided and required for all early childhood professionals, regardless of workplace.
     3) Flexibility MUST be given to the family (in choosing an early childhood program that works for the family’s needs) and program (in order to fully implement a high-quality curriculum that helps children learn and grow).

351. I’m happy to see the federal government providing this great guidance in the right direction. Lack of early care and learning programs with professionals who have the skills and knowledge to support young children in their national settings is lacking and a guidance framework such as this with recommendations to improve quality of inclusive practices in all early care and learning programs is needed.

     I would recommended defining or making a stronger the explanation of ALL early care and learning programs (child care center, home, HS, school district pre-k etc.)

     Also I have a fear that this may become an unfunded federal mandate similar to CAPTA. CAPTA’s heart and intention were and are in the right direction, but with limited resources, particularly to support professional development systems and quality improvement systems such as QRIS systems, putting many of these recommendations into place will be a challenge.

     Perhaps there is a way to funnel medicaid funding or 619 funding for eligible children to child care. Community based child care is where the majority of the children are. Having these funds tied to a programs quality improvement plan or IFSP/IEP to help individual children so they could use them to support onsite coaching and professional development would do wonders.

     Again I applaud the efforts to provide a framework for how states can work more collaboratively across systems to improve accessibility of inclusionary care in early childhood. Please help put the funding behind these recommendations.

352. I am a Deaf woman who went through her childhood education in an inclusion model, and I have to say my experience was the opposite of inclusion. Due to my hearing loss, no matter the accommodations provided me, I was not able to access the full experience of a typical student by the simple nature of not being able to understand the social environment around me, and as a result, spent many of my formative years profoundly isolated. This experience had such a deep effect on me I still carry it with me to this day and it shaped many aspects of my personality.

     For many students with disabilities, inclusion may be the answer, and they are entitled to an environment that helps them thrive and grow. However, for many Deaf and Hard of Hearing children, which I see in my daily work, being placed in an all-hearing environment is the very opposite of inclusion. I see children showing language deprivation syndrome, language dysfluency, behavior concerns that have developed as an adaptive response to not being able to communicate or be understood, depression due to isolation, and other evidence that shows they are in the wrong education environment just to service the idea of “inclusion”. Every student should have their education tailored to their needs, and inclusion is not the answer for everybody. “Inclusion” is not even mandated by IDEA. “Least restrictive environment” is, and that does not always equal inclusion into the general education environment. For a Deaf child, the LRE is an environment where they have full direct communication access with their teachers and peers. A place like this allows a Deaf child to thrive.

     This policy statement contradicts statements previously made by the Department of Education. The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     In addition, The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

     • I agree!!

353. As a person who was fortunate to be in an elementary school classroom with a special needs child, I am a firm believer that both the Gen Ed children as well as the special needs child or children can benefit greatly from the experience of being educated side by side with each other. Children with disabilities should definitely be included in early childhood settings in natural proportion to their presence in the general population. I hope that this public policy is embraced throughout the school systems of the nation to help foster the earlier development and intervention for children at all developmental levels.

354. “Early interventionists, Special Educators and Related Service Personnel should deliver services to children with disabilities in early childhood setting and embedded in everyday routines and/or co-teach and coach general early childhood teachers, as opposed to working with children in separate settings or pulling children out of their settings for specialized instruction.”
     As parent of a Down Syndrome son and two typical daughters with one high performance, I have dealt with IEP processes/goals/implementations every year but we need to re-focus on the individuals with special needs/education for the inclusion throughout their school-aged years not only early educational years. They learn slower but they do learn one subject at a time with constant reinforcement. Once they master the subject, they don’t forget so they can move on to another subject but not learning two or three subjects at a time. Therefore, we need to allow special education teacher to work with individuals and team up with regular education teacher so that teachers, in general, learn to teach and qualify for both general or special education. It’s all about being EDUCATORS (i.e. special need, general education, or gifted/exceptional). Since I’m a parent of all three categories, I know the children’s needs and even the gifted one requires different focus in educational settings but inclusion is the better way for all children to expose to all walks of life and to learn from personal experience/observation with parent/teacher/adult guidance.
     We all have different opinions. My opinion is not better than anyone but it’s my opinion from experiences (parent of 19, 13-DS, 8). I hope it would help law maker/administrator/teacher to work collaboratively for the sake of all our future children. Respectfully. TDuong

355. Inclusion is not just important for children with special health care needs but it is as equally important for typically developing children to learn how to work, play and learn with children who are different in some ways and the same in other.

356. Thank-you for this much need policy statement. My son with Down Syndrome has been in an inclusive preschool at our neighborhood school for the last two years. The exposure to typically developing children combined with the amazing staff and high expectations has resulted in amazing progress for my son. There is no doubt in my mind that he would not have made nearly as much progress if he had been in a non-inclusive setting. I also believe, and know that the research supports, that an inclusive setting is beneficial to typically developing students. That is why my typically developing daughter will be attending the same preschool next year as a tuition student.

     I would like to see additional policy statements extending beyond early childhood education into elementary school, junior and senior high school.

357. The Council for Exceptional Children supports the U.S. Departments of Education and Health and Human Services’ policy statement on inclusion of young children with disabilities. The scientific and legal foundations are strong. The statement is comprehensive and will offer the field many strategies to move the agenda forward. The statement is powerful, coming from two federal government agencies and places responsibility for implementation of the statement on both the early childhood special and general education systems and professionals. CEC stands ready to assist the Departments in implementation.

     Deborah A. Ziegler , Director of Policy and Advocacy, Council for Exceptional Children

358. What does Inclusion mean for a Child who is Deaf?
     • Accessible language as used by Deaf children, American Sign Language and English, including opportunities for language development
     • Direct instructions in the language used by the child by teachers and other professionals
     • Direct communication with peers who share the same language and communication
     • Full support for language and communication development for the child and family
     • Access to deaf and hard of hearing adult role models
     For the deaf child, full inclusion is not a placement but an environment where the child has full and direct language access with other children and teachers.

     The Department’s Definition of Inclusion
     According to Draft Policy Statement, On Inclusion Of Children With Disabilities In Early Childhood Programs, “The Departments define inclusion in early childhood programs as including children with disabilities in early childhood programs, together with their peers without disabilities.” The policy statement further explains that these programs include private or publicly funded center or family-based child care, Early Head Start, Head Start, private preschool, and public school and community-based pre-kindergarten programs.

     Who benefits from Inclusion as defined by the Department?
     Inclusion – as defined by the Department’s proposal – that may benefit a child with specific disabilities such as Autism may not benefit a child who is Deaf. Studies showing the benefits of inclusion for children with disabilities do not indicate whether these studies include children who are Deaf and use sign language. As a low-incidence disability, children who are deaf represent less than one percent of children with disabilities.

     The Ramifications
     A placement in an environment where a Deaf child cannot freely and directly communicate with peers and adults is not inclusive. It’s not enough that a Deaf child be in the presence of same-aged children without disabilities without access to meaningful interaction and direct communication. What happens when a Deaf child who uses sign language is placed in an environment with other children and adults do not use sign language? The end result is language deprivation and language delay that takes on a heavy toll on both the individual and society.

     One Size Does Not Fit All
     Each child with disability is unique therefore each child’s educational program needs to be individually tailored to the child. With respect to children who are Deaf and hard of hearing, the Department’s proposal conflicts with its policy statement issued in 1992 that placement decisions must consider the individual deaf or hard of hearing child’s language and communication needs. (1992 OSEP Deaf Students Education Services Policy Guidance Report, 20 USC §1414(d)(3)(B)(iv) and 34 CFR 300.324(a)(2)(iv)).
     Thus placement is not a one-size-fits-all but individualized to meet the child’s language and communication needs.

     Therefore, under no circumstances should any new policy detract from the individual child’s needs.

     Comments by NorCal Services for Deaf and Hard of Hearing,
     North Highlands, CA

359. Inclusion is not the LRE for a majority of deaf children. Deaf children need language as early as possible, provided by professionals proficient in ASL. Most deaf children placed in the general population are left out of social and academic events in the school setting. When the same children are placed in a setting for deaf children with access to language and peers, their language and social and academic progress parallels that of hearing peers. This progress does not happen in the general “inclusion” setting.

     This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

     I was “mainstreamed” in the general population. My mother had to work with me daily after school to make sure I understood what was taught that day. Socially, I could not develop because I could not communicate with my peers. Hence, I KNOW inclusion for deaf children is not the LRE for them.

360. This is great; however, there is NO mention of children with disabilities AND who are non-English-speaking. Somewhere the wording of the policy , ” including services for English Language Learner disabled children” should specifically be written in. Thank you.

361. My 4 yo daughter (who has Down syndrome) started preschool this year in an inclusive classroom, and the progress she has made this year is incredible! Her gross motor skills have improved tremendously, her social skills put her on par with her peers, and her speech took off the second half of the year. Not only is she benefitting, but so are her typical peers.

362. My son at age 2.5 needed speech services but even getting him diagnosed and into a program was hard and extremely expensive. Because he didn’t have an injury causing the severe speech delay, our private insurance wouldn’t cover even a diagnosis and hearing test. I happened to be at our area library and saw the sign for early intervention. I assumed that we wouldn’t qualify for Early Childhood services because of our income. I called anyway. No income qualification level and they directed me to a reputable hearing test at the health clinic that was $40, not $500. He went through 3 years of speech and OT through early childhood at our area cluster school for Early Childhood and then aged out into an elementary IEP for speech. I got lucky seeing the sign at the library. Publicizing the programs to all income levels and maybe through pediatrician offices to get the word out could save so many parents the heartache of considering the cost of private speech v. getting the help their child needs. In 7th grade, this child that had 6 years of speech is in the gifted program, accelerated classes and just got a 590 on his SAT. The therapists told us he was that child who would have never gave progressed unless he had early intervention. The program is so valuable but so under publicized and under used. 🙁

363. Our daughter is a 6th grader going into 7th grade. The transition is a tough one on me….but not so much for her. Because she has been included in class room activities with ALL the other 6th graders, and before that the kids in her elementary school, she has developed friendships that will help her cope with the change. What’s more important in the long range, is that these kids KNOW her. They understand her unique abilities and some of her disabilities and don’t mock her for them. Thanks to the Special School District for providing a caring INCLUSIVE educational format for the kids who can benefit from it.

364. Inclusion from birth is at the foundation of a successful life. Inclusion if early intervention sets up a successful base to enter the education world and allow all students a quality education. There are many studies that show all students benefit for inclusion.

365. Thank you for the work that went into the development of the new policy statement on inclusion. The fact that the US Dept of HHS and US Dept of ED created the policy statement together is cause for celebration. Too often inclusion is seen as a “special ed” issue; the collaboration on a joint statement sends a message that inclusion is about all early childhood sectors (pre-k; early care and education, Head Start, etc.). The clear statement that the new policy document builds upon the values, principles, and definition set forth in the2009 joint position statement on inclusion from NAEYC and DEC (page 3) is important in providing a sense of continuity and builds on the acceptance and use of that 2009 statement. I also appreciate the chance to share perspectives on the draft. I have two suggestions, one small and one at the big picture level, and one comment for consideration:
     1. Because the statement is long, many people will only read the Executive Summary without referring to the full document. I suggest including the point about building on the 2009 joint position statement on inclusion in the Executive Summary, so it doesn’t get lost. The three essential features of high quality inclusion defined in the 2009 statement…access, participation and support…are used often in public awareness, presentations, and other products. Those features are worth noting in the policy statement.
     2. Having worked very hard with a number of states in creating interagency task forces focused on coordinated early childhood professional development systems to support inclusion, I think the recommendations about creating an interagency task force and plan and building a coordinated EC PD system are notable and noble. What is missing is guidance on responsibility and leadership. Many states have numerous interagency task groups focused on early childhood, each supported by a different sector. They often do not work together. I suggest a statement about leadership that can bring together the sectors in a unified effort to build the knowledge and competency base, etc. Without a powerful leader organization, this could be one more group with a similar mission as multiple other groups in a state.
     3. How might implementation science be brought into the efforts to advance inclusion?

     Thanks again for the chance to comment

366. I cannot express how important I feel inclusion is for both our children with disabilities and children without them. My son has Down syndrome and has been in an inclusive environment for both daycare and school. He is now in first grade. Children learn a great deal from being around their own peers, despite what their abilities are or where they are on the milestone “charts”. One of the other values is that children develop a sense of belonging that may not occur if not in an inclusive environment. The value doesn’t stop there…. the children without disabilities also gain and learn from this experience. Things like diversity, tolerance, patience, understanding, being helpful…. the list goes on… Inclusion should be a “given” in our society. Our children and not going to go away. They are part of our lives, our families and our communities and deserve to have an inclusive environment during their entire lives.

367. I believe that children with disabilities should be included in early childhood settings in natural proportion to their presence in the general population. My son has Down syndrome and inclusion helps them feel accepted, not so different and really encourages education. My son attends the Boys and Girls club I can see a big difference. He has more confidence and he brings home homework and works on it. Inclusion is the key.

368. The need for inclusion in human interactions beings at birth. The need to expand these interactions and related activities increases with age. It is inappropriate to exclude children with disabilities from activities. They, too, should be exposed to rich experiences where they can learn in the context of play and everyday interactions and engage with their peers with and without disabilities. LINKS Mat-Su Parent Resource Center applauds the efforts being made byThe U.S. Department of Education and the U.S. Department of Health and Human Services.

     Eric Wade

369. My daughter is 29 and I insisted on her being included always. She was included in preschool, daycare, Sunday School, sports, band, and in all her educational settings. She’s confident, has a mind of her own and can get up in front of an audience and speak better than I can. She’s appropriate (most of the time:)) and she learned this in the regular classroom along side her typical peers while they learned it. She heard the speech of typically developing students and that’s what she copied. Inclusion is the right thing to do and to me there is no one that should not be included. It disappoints me greatly when I see parents of young children still fighting for inclusion. This should not be happening.

370. As an early childhood special education teacher who has worked with children with mild to severe disabilities, I want to caution against laws/regulations/policies that force an ‘all for one’ type approach. Some children benefit from fully inclusive educational models, while other children require a different setting or different approach to meet their individual strengths/challenges. I find it hurtful and offensive when I read policies/regulations that imply special education settings are not up to standards, or when I hear professionals speak poorly of specialized instruction or special education. I have and will continue to push all of my students to high standards. I deliver instruction targeted to individual student needs while keeping track of local and state standards. One size or ‘policy’ does not fit all children. I have personally watched children meet with frustration in inclusive settings where professionals worked very hard to provide for students. I have also watched children thrive when they were educated in settings that were more conducive to individual learning/sensory/behavioral needs. Our greatest goal should be to educate each child to his or her fullest potential, not to lock all children into one square room simply due to policies and laws.

     • Thank you for your work.

371. As the parent of a child with a disability, I support your proposals for inclusion of all children with disabilities in high quality education programs. Our daughter is now in high school and still meets with resistance from school personnel regarding her rights to be included. During her preschool years we advocated for her right to be included with appropriate supports but were not successful in convincing the school system. We ultimately enrolled her in a private preschool at our expense and paid for the services she needed. I firmly believe she rose to the occassion and is better off as a result, even now. We hope that the Department of Education will put some effort into enforcement of this proposal when adopted so it’s not always left up to parents to find the answer for thier children. They deserve your support and your action, not lip service please. Thank you.

372. As someone who’s daughter with Down Syndrome was not able to attend an inclusive pre-school, I endorse the statement made by the US Department of Education, with the modified suggestions made the NDSS. Having observed and met Down Syndrome children in more affluent surrounding towns who were able to attend an inclusive pre-school, they possessed greater social and academic skills. Luckily, she will have an inclusive environment for elementary school, but I can’t help but wonder how much more capable she would be had she had that same experience the past two years.

373. I am the parent of a 4 year old boy with Down syndrome who is transitioning to Kindergarten this fall. I am an advocate for all people with developmental delays and disabilities.

     Inclusion is crucial for EVERYONE. That includes children without disabilities. Students with disabilities learn better in a general education classroom as long as the proper supports are in place and staff has the proper training. Students without disabilities perform just as well in inclusive classrooms and they also learn about empathy and understanding.

     My son participated in a new preschool program this year where he was in a private preschool with a special ed teacher and supports. It has been amazing. The class was split evenly between typically developing children and children with special needs. We have seen amazing progress this year and I owe much of that to his fellow classmates.

     Unfortunately the interpretation of inclusion is loose to say the least. It’s time change that. We don’t need to segregate children with disabilities in schools any more. If we segregate them in preschool – how can we expect them to be together as adults?

374. My daughter Lillian is 9 years old– and she is thriving with her Down Syndrome in large part due to her excellent educational start at a private montessori school. How amazing would it be if every child with special needs had the opportunity to attend an excellent preschool with inclusion as a goal? I cannot say enough about that early investment in our kids.

375. NDSS and NDSC have spoken here for me, a parent of a child with Down syndrome. So let me add the heart, as I am in the process of exploring an ideal setting for my child in intermediate school. I am SO GRATEFUL for the opportunities I have had in my public schools to keep my daughter in an inclusive setting. She has learned the behavior skills, appropriate social skills and academic expectations (adapted to her level) to participate meaningfully in every new environment she faces. Had I allowed her to be placed in a specialized environment, she would have risen only to that expectation for her future. Instead, I have a student who I am confident will be able to access higher education and lifelong learning experiences as they become available to her throughout her life. To that end she continues to learn to advocate for herself in a population that looks more like the rest of the world she will live in. So I applaud and support the “critically important recommendation in the policy statement . . . that the inclusion of children with disabilities be in proportion to their presence in the general population (natural proportions).

     • I am a teacher and a mother, I believe that children with disabilities should be included in early childhood settings in natural proportion to their presence in the general population.

       Value diversity and inclusion for all

376. First I applaud the efforts of two federal departments working collaboratively on behalf of children.
     Unfortunately, as an advocate, I cannot support a “one size fits all approach” for children.
     IDEA clearly states, “least restrictive environment” based on the “individual educational needs of the child”. The continuum of appropriate options should be afforded all of our children.
     Our organization provides a full continuum of high quality early education programs where children can move along the continuum based on their individual needs. Children are placed in integrated environments with necessary supports to help them be successful in these dynamic classrooms. We are not “anti-inclusion” rather opposed to wholesale programming.

377. Thank you for encouraging inclusion for pre-school students with disabilities. As a parent and advocate for inclusion, I have personally watched (and fought) against increased separation of preschool students with disabilities in my city (Springfield, Missouri). I watched as preschoolers with disabilities were removed from their neighborhood schools and placed into separate centers, while Title 1 students remained in these neighborhood schools. There are some specific issues that need to be explored:

     1) SETTING: States and districts must make sure that Head Start (Title 1) classes are in the same schools as preschool students with disabilities. As class space becomes limited, the go-to answer has too often been to place preschool students in trailers on school property and then to even more-separate settings.

     2) FACILITIES: As districts build new schools, class space needs to be planned for preschool classes. This may be mandatory elsewhere but is not currently considered in my district.

     3) POLICIES: One reason our preschoolers with disabilities were separated was due to state policies that allowed districts to lease properties (where lease amount included renovations) away from school properties. One lease was $625,000 a year. In my opinion, that money should go into creating inclusive classroom settings in neighborhood schools.

     4) IDEA: While I believe the strong wording and compliance issues in the draft will have positive impact, the statutes in IDEA must be modified to reflect the proposal if true, long-term change is to occur. Parents and I took our local separation issue to the Office of Civil Rights and was ultimately told that our case could not be pursued due to how regulations are worded for preschool-age students in IDEA.

     Thank you for allowing us to make comments on this proposal. I am available for questions.

     Sincerely,
     Vicke Kepling

378. Children with disabilities should be included in main stream classrooms in natural proportion to their presence in the general population. All children achieve in response to expectations and experience. Mr beautiful granddaughter should be in ab inclusive environment that models our high expectations for her

379. The new policy statement is much needed to encourage and support school districts in providing inclusive environments for preschool students. Thank you!

380. Thank you for a powerful, comprehensive, and thoughtful statement. The statement in many ways fulfills the promise of IDEA, the desires of tens of thousands of families, and the societal compact to provide best evidence practices (inclusion being one) for young children with special needs and their typically developing peers.

381. The National Down Syndrome Congress wishes to thank the U.S. Departments of Education and Health and Human Services for the draft policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. We especially appreciate the comments in the policy statement, which emphasize that the policy applies to students with significant disabilities and mentions some of the critical skills they develop in inclusive environments.

     The policy also makes the point that the benefit of early childhood inclusion can be lost if children do not continue to be educated in inclusive settings when they reach school age. The continued inclusion of students with disabilities in general education classrooms is directly related to post-school success. This is also true for students with the most significant cognitive disabilities, as discussed in a National and Center and State Collaborative paper on College and Career Readiness (http://ncscpartners.org/Media/Default/PDFs/AA-AAS-College-Career-Readiness-NCSC-9-24-2013.pdf). However, as the paper points out, less than 7% are educated in general education classrooms. This unfortunate trajectory usually starts in early childhood and preschool.

     The recommendations offered in the draft policy for expanding inclusive high-quality early learning opportunities for all children are extremely important. Many of them would also apply to the implementation of the Least Restrictive Environment provision in the Individuals with Disabilities Education Act for elementary and secondary education. One critically important recommendation in the policy statement is that the inclusion of children with disabilities be in proportion to their presence in the general population (natural proportions).

     NDSC is looking forward to the release of this draft policy statement in its official form as soon as possible. To support the implementation of the recommendations in the policy statement it will be important for two changes to be made to the OSEP 618 Data Collection rules for early childhood education.
     • Currently an early childhood setting is counted as a regular early childhood program if it has more than 50% nondisabled children. The current 50% rule should be changed so that only a setting that has a natural proportion of students with disabilities (approximately 10-12%) is considered “a regular early childhood program.”
     • At this time, the data collection does not distinguish between a child attending an early childhood setting in a regular education early childhood program that is provided or paid for by the school district and one for which the parents are paying tuition. The data collection should be changed to reflect this important distinction and ensure transparency about whether the district is providing the least restrictive environment for early childhood education.

382. early intervention is really important and having specialists in inclusion for the early years to advise pre schools is necessary to train staff and include all children.

383. Thank you to the Departments for this joint policy statement. It concisely outlines that the literature and legal foundations support for inclusion while clearly stating that IDEA requires individual decisions. The statement identifies the important provision of IDEA that requires that when making LRE decisions for any child with a disability, the regular education placement must be considered first with supplementary aids and services (sec. 300.114). Supplementary aids and services are defined very broadly as supports to enable children with disabilities to be educated with nondisabled children (sec. 300.42). IDEA also requires that teachers and administrators receive training and technical assistance necessary to assist them in implementing the LRE (sec. 300.119). Perhaps add the IDEA regulation citations? Thank you also for including all the resources to help families, administrators, higher education faculty and direct service providers provide high quality inclusive services.
     I have three suggestions, 1) please use the term early childhood special educator(s) when referring to special education. ECSE is a recognized field with it’s own professional organization (DEC), body of research and standards of practice. Professionals with this preparation have competence and skills in early education as well as special education and are trained to partner with families; 2) include families as members whereever there is a recommendation for a collaborative body both at the state and local level; and,3) since the lack of awareness of the benefits and legal foundations for early childhood inclusion is the number one challenge, add a section to the local recommendations that suggests that the state and local advocates engage in activities to raise the knowledge base of local administrators, principals and family members so that they can make well-informed decisions. Thank you!

384. The National Down Syndrome Society (NDSS) is the largest nonprofit representing and advocating for people with Down syndrome and their families, with a network of 375 NDSS affiliate organizations spanning all 50 states representing over 400,000 people with Down syndrome. NDSS strongly supports the draft policy statement proposed by the U.S. Department of Education (DOED) and the U.S. Department of Health and Human Services (DHHS) which encourages the inclusion of young children with disabilities in high-quality inclusive early childhood programs. NDSS also shares in the vision that all Americans, especially individuals with Down syndrome, be meaningfully included in all facets of society throughout the life course.

     NDSS has heard countless stories from our advocates about the benefits of inclusion in early childhood programs to both children with disabilities and typically developing children. When children with disabilities are included, they tend to have higher levels of social play, cognitive skills, motor skills, self-help skills and speech gains as they learn through peer modeling and social interaction. For typically developing children, studies and anecdotal evidence have shown that having peers with disabilities in their classroom makes them more empathetic and open-minded, and have better coping skills with setbacks and challenges.

     NDSS supports two proposed changes to the draft policy:

     (1)The definition of “a regular early childhood program” should be changed from one which contains 50% nondisabled children to one which contains a natural proportion of students with disabilities (10-12%) (this will better reflect society’s ratios); and

     (2)Office of Special Education Programs data collection should distinguish between a child attending a program that is paid for by the school district from a private program that is paid for by the parents (this will ensure transparency in the district’s role).

     NDSS would like to thank DOED and DHHS for this important policy statement, and hopes that it will be released in an official version as quickly as possible.

     Sincerely,
     Sara Hart Weir, MS
     President, National Down Syndrome Society
     sweir@ndss.org

385. I would like you to stop the Department of Education from issuing a policy of inclusion that violates the requirements of the Individuals with Disabilities Education Act (IDEA) that will keep students with disabilities from being served appropriately. The law requires Least Restrictive Environment – most appropriate environment – and does not support a one size fits all system for all children with disabilities. Inclusion is a great idea for those that it works for. It doesn’t work for everyone. My son needed to be placed in a special therapeutic day school in order to educate him properly. They tried inclusion, it didn’t work. The school didn’t have the resources

386. MY CHILD WITH DOWN SYNDROME WAS IN AN INCLUSIVE SETTING IN PRESCHOOL AND IS NOW GOING INTO THE 4TH GRADE WHERE SHE IS STILL IN AN INCLUSIVE SETTING. SHE HAS DONE SO WELL BEING EDUCATED WITH NON-DISABLED PEERS. HER SPEECH AND INTELLIGIBILITY HAVE MARKEDLY IMPROVED OVER THE YEARS…BY ALLOWING HER TO BE EDUCATED WITH HER PEERS, WE HOPE TO ATTAIN A BETTER OUTCOME FOR HER AFTER HIGH SCHOOL.

387. Absolutely, children with disabilities should be included with their nondisabled peers! At this early level, in support of their inclusion at other levels of their education — and the rest of their lives!
     The laws have been in place for many years. It’s time for ALL local schools to embrace the inclusion model wholeheartedly.

     • My question for special educators-

       I am not speaking of deaf children coming from families with lots of support at home. It is a small percent. I speak for deaf children who come from Spanish households and families who are not able to invest their time to support their children in mainstream program? More than 50 percent. What happen to them? Too many of them do not have goals to go to college or higher level of education after graduation. More students are slipping through the cracks. It is very difficult for a child to know what is going in the environment. (School and home) Have to rely on interpreter all the time. What about their social skills? Recess, lunch, sports, organizations, and side conversations with peers heavily weigh on social skills. It is not simple as you thought. Interpreter can’t be with the student at all times. It is most restrictive environment for a child. It is easy for special educator who decide to make a placement for deaf students with students who do not have disabilities but do not have the experience as a deaf student going alone in public school. I had my moments. If I can go back, I will choose to attend a deaf school. I will be a whole person with lots of role models for me to interact on the campus. You had no idea how it can be very lonely to depend on interpreter all day. If all public students know how to sign at school. It will be a different story. It is all about direct communication. All public schools do not offer any direct communication. Resource room can be very isolating. Depends on one or two teachers all day.

       This is very serious issue that I kept seeing many problems from special educators who do not make time to visit both deaf schools in California. They need to open their eyes and see the difference between mainstream program and deaf school.

       It always break my heart to see many deaf students going through hard times. They already have struggles at home. Lots of families do not know how to sign. They miss out too much information. School districts do not offer any ASL classes in their local programs. Parents have to pay for it so they can communicate with their children. Often, parents refuse to pay for ASL classes. It costs money for parents. School districts should be responsible to cover the cost to make sure that parents have access to communicate with their deaf children. Too many deaf children need help with homework but parents do not know how to sign. As a result, the cycle continues for a child to struggle and learn.

       Who make those decisions without any experience of growing up in the mainstream program?

       Something to consider before you assume to place all students with students who are not disabilities. Not all of them know how to sign.

       Isolation is a big issues for deaf children when it comes to social time at public schools.

       Try to imagine and put ear plugs. Walk around in the public school. Walk through the hallway, cafeteria, recess time, side conversations with peers. You will notice how much information you would miss out.

       A child at a deaf school do not experience any problem. The child can walk through the hallway. She can watch students and teachers sign, sit on the cafeteria table and watch students signing to each other, including three or four tables away- a student is still able to understand. When it comes to recess time, a student can play with many students and see what they say, even through they can stand far. They never feel the need to depend on interpreter. They can have full direct communication anywhere they go on the campus.

       Please consider this a favor to visit both deaf schools in California.

       It will enlighten your heart to see how deaf children can function just like other students who do not have disabilities.

       Often, I see people thinking that state schools serve students with severe disabilities. It is not true. Both schools serve to all students who are in special needs, regular, and honor/AP classes. We use direct communication.

       How can it go wrong for students to have direct communication with teachers? Just like other public students with their teachers.

388. I truly like inclusion for young students. While I support this change, I know that inclusion does not work for all students. There are some students with very intense disabilities that would jeopardize all students. Provisions and resources are needed to address these concerns; so that, these students can participate in a full time inclusion setting.
     With this inclusion proposal, typical students can develop an awareness and respect for those who are different. This is the ideal preparation for entering the workforce. It’s best to
     start in then early years and continue for life.

     I hope that this proposal will be implemented in pre-school, elementary, high school, technical/vocation, and college/university. Not only do I wish for across the board implementation, I also hope that there will be funds and resources available to individualize this program. To that end, I have concerns about accountability of the program. Currently, the public schools have a very loose supervision of special education laws.

389. I’m from the UK and this my area of work. We have an early years Sen team, and my role is to model stratagies to staff that work with children with Sen in preschool, (under 5’s). I help the setting to become inclusive and differentiate the play, resources, work with other professionals to plan the education and set iep targets. Wish I could get a job out there in the USA and do the same thing.

390. Inclusion is not only beneficial for children with disabilities but also for typically developing peers as well. Instilling empathy and compassion in children during formative pre-school years can help suppress the urge for them to bully others as they mature. Blending classrooms in an inclusive manner will ensure that typically developing children are exposed to peers struggling with learning and/or developmental disabilities. As such, learning communities can form which foster respect, cooperation and teamwork.

391. I had a TBI at the age of 5 or 6. This lead to be a slow learner, mental illness, and a host of other disorders. I was kept in the regular classroom at a time when special ed. was non-existent and expected to keep up. While still experience some things at a slower pace, I deal with life reasonably well. Early intervention is critical and extremely important to all individuals, and inclusion is vital to children at all levels of schooling to prepare them for adulthood.

392. Its great news to hear that The U.S. Department of Education and the U.S. Department of Health and Human Services are proposing to release a policy statement on inclusion of young children with disabilities in high-quality inclusive early childhood programs. Integration is welcomed and the social benefits would be obvious. However, The Dept of Ed must keep in mind that services must be in the Least Restrictive Environment/Natural Environment in conjunction with what is stated in the childs IEP. The IEP/IFSP is developed by the full team of professionals with the best interest of the childs specific needs in mind. All Dept of Ed rules/regs should support current law not Department’s philosophy. The law ensures that ALL students are served based on their individual needs, it works if implemented correctly. This policy is trying to push one placement over another, this is not your responsibility, this responsibility belongs to professionals and parents. Please help to appropriately implement the current law, not set policies that contradict current law.
     Some reasons why group push in serves within the classroom do not work in all cases are below:

     1. skill specific treatment does not always coincide with what a classroom has planned on a specific day.

     2. social sigma (example shoe tying, writing skills) psychological wellness is part of treatment.

     3. sensory treatment does not work in the classroom…almost all “sensory diets” involve removing a child from classrooms.

     4. limited access to all therapy tools available is what results from a push-in only mandate.

     Thanks,

393. As a parent of an older student, about to move out of k-12 and into post secondary life, I have a longer perspective. We have also been a mobile family, moving with educational goals, the military and for our children’s best interests.

     The research has been clear for over 40 years that inclusion and high expectations (academic and behavioral) make a substantial difference in ALL at risk students. I do not understand why we are still debating this.

     In our personal situation it is clear. Full inclusion in private preschool, full inclusion in k-7 in great setting in Florida (St. Paul’s preschool, Niceville–near Ft Walton Beach) and Ann Arbor, Michigan (Angell Elementary and Tappan Middle) made tangible, measurable differences in our daughters academic and social abilities. At this point we moved to Seattle for employment reasons. We were profoundly saddened to find most students with Down syndrome were placed per diagnosis alone into “low functioning” contained classrooms… 40 years of research ignored and countless students left to under-perform and live on public assistance in poverty. We fought for our student to be included and raised the expectations of the teachers/staff/peers to the point she graduates and is moving on to community college.

     Why, because we did not put preconceived limits on her ability, we supported where needed and expected her to perform. We are now showing and mentoring other parents so that they too can conceive of a future for their children that includes academic ability, peer relationships and purposeful employment.

     Fully funded teachers, professional development, supported classrooms, smaller classes are best for ALL students.

     Having a NATIONAL STANDARD for inclusion, ENFORCING LEAST Restrictive Environment is essential for lifting kids at risk out of the trenches of poverty.

394. i think it’s an excellent idea! Thumbs up!

395. My 5 year old was in an inclusive preschool for 2 years. The children were talking circles around him and he was soaking it all in. When he started talking I found him picking up quickly on vocabulary and understanding more than I thought. They practiced writing his name with him and numbers, he wasn’t doing those things yet, but the exposure was all he needed. When his fingers were stronger to hold the pencil with a good grip he wanted to write his name like the other kids. His brain was making connections with the world around him and I believe early exposure and the constant motivation from watching typical peers is what helped develop him into who he is today. Now he talks circles around me. Thank you for this article and I will gladly pass it on.

396. How delightful to hear that a policy may be released and that young children with disabilities will be in high-quality inclusive early childhood programs.

     You see, I AM “INCLUSIVE EDUCATION !”

     Let me clarify – I am a typically developing person who had the privilege of being included with a person with IDD (Intellectual and Developmental Disabilities) while we were both in elementary, middle and high school.

     I learned so much from being included with her. I learned things that no text book, map, video, app, movie, blog etc. could ever teach me.

     Despite all my efforts, it is still hard for me to put into words what those formative years and diverse experiences day in and day out, year after year, with a person with intellectual disabilities taught me.. But I will try…

     …I learned better how to be a human and how to interact meaningfully with other humans. I think it taught me to appreciate different styles of being and becoming. It taught me to strive harder through adversity, to be more open to others and to challenge and change my perceptions of people and their perceived “shortcomings”, to appreciate the small things that life sent my way, to enjoy each day as I got a new day, and to attempt to be more kind in deed and action.

     My early inclusive experiences taught me how to be strong, braver and more humane. I had early opportunities to see the adversity some people face and those experiences inspired me to fight discrimination when I could. I now count many people with IDD as my friends and I believe i am emotionally richer for it.

     When I found out that the person I was dating had a child with autism and that I would eventually be this child’s step mother and then, later, when I became the mother of an adorable baby boy with Down syndrome the world of IDD did not seem as “scary” or “alien”or “impossible” to me. I think I currently deal better with what life sends my way due to my early inclusive experiences.

     I have been a classroom teacher. Please realize that about 10-12 percent of students have special needs and each ideal classroom should be made up of a similar proportion of special needs students.

     It is also my hope and dream that “meaningful” inclusion is part of a person throughout their life span. We have a long way to go, but then I also see how far we have come and I am inspired by people and offices like yours. Thank you for this important policy statement

397. My daughter will be entering Kindergarten this year and I’m so excited for this proposal which will continue to promote her inclusion alongside her typically developing peers. My daughter has Down Syndrome which, combined with other factors of her personality, can sometimes make it difficult for her to communicate her talents and skills. So many people, especially educators and therapists who have interacted with her throughout her early intervention program, have showed us how easy it is to expect more from our daughter. We have, unfortunately, also seen those who treat her as less capable than she is because of how she presents. She is short in stature and looks younger than her age and capabilities. I believe it is important for children with all types of abilities to be included proportionally in the classroom so that they can be challenged to rise to their abilities and so that all children can grow up in a culture that recognizes the value of each person. We recently became aware of another child with Down Syndrome that will be in the same school as our daughter and we are hopeful that the district will recognize the value of splitting them up into different classes so as to provide a more representative classroom environment for all students but also so that they are not continuously placed together in the “low expectations” group. Our children have so much to offer and so much to gain from inclusive practices.

398. I am a special education teacher and a mother of a young child who has a disability as a result of her having down syndrome. My daughter has been in a daycare preschool since was a baby that was not a specialized school. She uses this preschool as daycare for evening hours. She also attends a specialized preschool 1/2 day and a non specialized preschool the other 1/2 school day with her non disabled peers. She has made specific kinds of gains in each setting that she could not make in the other. It is my conclusion that children with special needs would benefit from both settings and the decisions to be made about placement should be based on each individual childs needs.

399. Inclusion in preschool is the stepping stone that promotes inclusion into Kindergarten and then into elementary education. I have an 8 year old that experiences Down syndrome that was allowed to be included since her daycare program and has continued in our neighborhood school with her ‘typically’ developing peers. This is the beginning of an inclusive society for all people. Research proves that inclusion benefits not only the students with disabilities but ALL students in the classroom. We live in a society where people are unique and we need to show and embrace the uniqueness of every person and this begins in the early years of preschool. All means all!!!

400. The American Speech-Language-Hearing Association (ASHA) is pleased to have the opportunity to comment on the draft policy statement on inclusion of children with disabilities in early childhood programs. ASHA is the national professional, scientific, and credentialing association for 182,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Audiologists specialize in preventing and assessing hearing and balance disorders as well as providing audiologic treatment, including hearing aids. Speech-language pathologists (SLPs) identify, assess, and treat disorders of speech, spoken and written language, cognitive-communication, social communication, and swallowing. More than half of ASHA’s members work in a school setting as part of the education team; therefore, this guidance document directly impacts our membership.

     Overall, we applaud the U.S. Departments of Health and Human Services and Education for this important policy statement that sets a vision and provides recommendations for increasing the inclusion of children with disabilities ages birth through five in high quality early childhood programs.

     Thanks for your support in the policy statement of: (a) the importance of fostering communication, among other things, in inclusion in early childhood programs as the development of communication skills begins at birth, and (b) the important role that related services providers/specialists, specifically speech-language pathologists, play in providing services and supports that young children will need in order to be successful in inclusion programs.

     Effective communication is fundamental to early childhood development; it is foundational to learning, conduct, and literacy. Inclusive practices enhance the communication skills of children with and without disabilities. It is important to highlight related services providers due to the specialized services they provide, and the policy statement does that in a number of places.

     ASHA looks forward to continuing to work with ED and HHS on this very important issue.

     • Please refrain from your statements of making it look obvious your people want to “fix” us, the Deaf people. You and your people need to embrace American Sign Language and encourage Deaf children to learn ASL. It is one of the most beneficial language. Hearing people need to STOP trying to run or control Deaf people’s lives. We are very much capable of making our own decisions that works for us, we do not need your people to do this for us. Speech does not work for us or help us improve our reading/writing but ASL does. Please keep your audism thoughts to yourself and embrace ASL.

401. As a mother of a 3 year old with Down Syndrome, who is transitioning out of her current birth-3 yr special ed program, I fully support this policy.

     Our community does not offer an inclusive pre-school option with special education support. We were offered the option of two different special ed preschool settings, which would include children 3 – 6 years old, or we could find a fee based program and bring her to the district ourselves for occupational therapy and speech language services once a week.

     As parents, we decided the special education preschool setting was not in the best interest of our child, and chose to find a fee-based development center which offers no special education supports. With this choice, we are now facing the financial difficulty of paying for her tuition AND of having to arrange and provide transportation for her weekly OT and Speech/Language.

402. This is a great statement! Outcomes are so much better for preschool-aged students (and all students) who appropriately receive their services in an inclusive setting. I fully support this position as it is desperately needed!

403. On behalf of the Autistic Self Advocacy Network, I would like to applaud the Department’s support for inclusive early childhood education. We support this policy and hope it will be officially released as soon as possible. The clear message in the policy statement about the benefits of inclusion and the resources provided in the appendices will help our members and their children as they seek to be more fully integrated into inclusive classrooms and other early childhood environments. An especially important recommendation is the inclusion of children with disabilities in proportion to their presence in the general population (natural proportions). The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond. We strongly support the Department’s statement and recommend that it be issued in its current form.

     Warm regards,
     Ari Ne’eman
     President
     Autistic Self Advocacy Network

404. Please include specifics about inclusion for special needs children including needing paras or other full time assistance for educational needs, including sign language to communicate. Alternate educational means should be available, i.e. visual learning tools. Thank you for including children with alternate needs into regular classroom settings.

405. I fully support children with disabilities having the option to access high quality inclusion classrooms. With that said, it is important to note that The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require that children with disabilities have access to early childhood programs. My concern is that the language of this policy statement implies that general education environments are the best and least restrictive environments for all students. Please note that students with disabilities are a hugely heterogeneous population and for some, inclusion in general education environments equals exclusion, both educationally and socio-emotionally. I work at a school for the Deaf and can cite countless cases of students who arrive to our school in high school with linguistic, academic, and social delays after spending years struggling and feeling isolated in mainstream classrooms that were not able to meet their individual needs. For many deaf students, being in a visual language learning environment is ideal, as significant portions of information are missed in oral classrooms, even with the use of qualified sign language interpreters. Schools that facilitate direct communication between students and teachers (as well as among students) promote full comprehension and opportunities for meaningful socialization. There are certainly deaf and hard of hearing students who are able to thrive in general education settings with the use of interpreters, but assuming that such settings are appropriate for ALL deaf and hard of hearing students does them a disservice. Please consider the value of the services and opportunities that students receive when attending schools designed to meet their specific needs. Early education programs for deaf and hard of hearing students provide early exposure to signed language (which is crucial for their overall language development), specialized resources, and Deaf mentors and role models who help set high expectations for these children’s educations and lives. Children and families absolutely have the right to access high quality early childhood programs. Please continue to also support their right to choose specialized schools and programs that are designed to meet their individual needs.

406. Inclusion is important. I believe that children with disabilities should be included in early childhood settings in natural proportion to their presence in the general population.

407. TODAY, as I drop my five year old, Macy off to her LAST day of preschool this morning…I am experiencing the same range of emotions any parent would in this situation. But I must say, my feelings of GRATITUDE overwhelm & overshadow any other.
     I am GRATEFUL for ALL the inclusive opportunities that have been extended to her…at Sunday School, Wednesday night church classes, ballet, tap class, gymnastics, swim lessons, and ESPECIALLY SCHOOL!

     My heart is happy…but also sad. I am sad, and a little mad, because I have come to learn this is NOT the educational experience/setting most children with Down Syndrome (here in NE and/or across our country) are offered.
     I believe that children with disabilities should be included in early childhood settings in natural proportion to their presence in the general population…this translates to my hope that Macy and her friends will also be meaningfully included in all facets of society throughout the course of their life.
     Yes, Macy benefits from private therapies, and many “specialized” programs that cater towards individuals with Special needs…but these programs are supplemental and help to lay the ground-work, ensuring as much success as possible in the inclusive setting (both in the classroom and OUT).
     ———————

     quote from Sara Hart Weir – President NDSS “When children with disabilities are included, they tend to have higher levels of social play, cognitive skills, motor skills, self-help skills and speech gains as they learn through peer modeling and social interaction. For typically developing children, studies and anecdotal evidence have shown that having peers with disabilities in their classroom makes them more empathetic and open-minded, and have better coping skills with setbacks and challenges.”

     As a parent of a child with Down syndrome, I strongly support the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education and commend the Departments on their collaboration and excellent policy statement.

408. Include all children in high quality programs and schools.
     Children with disabilities can only benefit from being in an inclusive environment and modeling and socializing with their peers.

409. I have worked in the field of early childhood special education and mental health for over 30 years. Inclusion of young children with disabilities in high quality early childhood settings is imperative. This policy effectively advocates for inclusive early childhood programming by recognizing the benefits and also the challenges.
     As this policy seems to acknowledge, it’s one thing to mandate LRE – it’s another to implement it.
     Essential features of early childhood inclusion must be addressed: Appropriate child to staff ratios, well-trained early childhood educators who are paid and respected as professionals, effective supervision and support for the workforce, universal preschool, and early intervention specialists who are reimbursed for and trained to deliver services in typical settings. Additionally, effective inclusion requires compatibility of policies that span the varied publicly funded early childhood programs. As long as Head Start Performance Standards, State Early Learning Standards policy, State Pre-K program policies, Early Intervention Regulations and policies are separately applied, how will we include all children successfully? The reimbursement policies for services must also be addressed. In special education these policies (e.g., Medicaid reimbursement for 1:1 therapies; free tuition for special education classrooms vs tuition costs for typical preschool placements) reward pull out and specialized services, not inclusive, collaborative approaches. Pre-service and in-service education must prepare and support professionals in inclusive education practices.
     I applaud this policy.
     Thank you for the opportunity to comment.

410. This does not apply to Deaf and hard of hearing children. This could be detrimental to their education. I understand in theory how inclusion sounds good, but simply putting our students in the general education classroom is not always meeting their needs. LRE means the place where they have complete access to language, and sometimes inclusion does not provide that. I have been a part of districts that simply want students to experience inclusion, but that does not meet their needs. It is important for our students to have access to language models, sign language support, peers, family support, Deaf culture, cochlear implant/hearing aid support.

     • I have been deaf in one ear since I was five and learning how to hear in situations especially education is essential to the growth and development. The point is long term development. If you pull a child out to learn they can’t function in our society and others around them won’t know how to learn to support others in this situation. We are all equal with equal rights. We need to know our responsibilities together as a collective society.

411. I’m a Deaf person who went through the education system of a Deaf school. I also am currently a Deaf Educator and a parent of two Deaf children. Inclusion sounds nice, but is not the LRE for some students, specifically, those who converse primarily in another language (ASL in the case of Deaf students).

     Way too often Deaf schools get a new student in the 5th grade who is severely delayed in basic academic skills because they spent their early years trying to be “included”. And in the process of being included, they lost out on the ability to learn academics via their natural language.

     Here are a few more points to consider:
     • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion. 

     • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.  

412. The Department’s position “that all young children with disabilities should have access to inclusive high-quality early childhood programs, where they are provided with appropriate support in meeting high expectations” is right on target. As the parent of a 12-year-old daughter with Down syndrome, I can say that without question, her ability to do amazing things has been directly inspired by her opportunities to do, along with typically-developing people, what they do. Never under-estimate the power of a human being to learn and achieve, and that begins with letting a person know from birth that they are “able” like anyone else, even if they might need some help.

413. I agree with a lot these posts. I am a survivor of the special education classrooms of the 1980’s and 1990’s. I put that literally. Being put in a classroom with all different diagnoses is dangerous. I was with mentally disturbed and emotionally disturbed children that threatened my life on a daily basis. I was treated like an out cast by my peers just because I learned in different ways and at a different speed. I have a high IQ and had an IEP but was excluded from all regular education classes until my Mom fought for me to be mainstreamed in my senior year. Educators think they know what is right for us but they are wrong. I was told by teachers and counselor of the school district that I would never be able to handle going to college. I graduated with a 3.1 in December 2014 from Pennsylvania College of Technology. I was encouraged their and they have the best teaching, tutoring staff you’ll ever want. I am glad I went back to school. I am here to say I am an INCLUSION CONSULTANT and I am changing the way education is treating children like me. Do what is right for children like me. we deserve a chance to be included.

414. I am the parent of a child with a disability and I support the draft policy statement proposed by the U.S. Department of Education and the U.S. Department of Health and Human Services which encourages the inclusion of young children with disabilities in high-quality inclusive early childhood programs. My son was included in private preschool, which brought great benefits to him and his typically developing peers. Unfortunately, he did not have the option of inclusion in a public preschool. The only option that our school district offered to him was a fully self-contained preschool classroom.

     I do support changing the definition of “a regular early childhood program” from one which contains 50% nondisabled children to one which contains a “natural proportion” of students with disabilities.

     Thank you very much.

415. Early Intervention – is another topic. My daughter, Mary, is evidence that early intervention is a MUST. We took every advantage of the resources available to us and diligently worked with her therapists for the first three years of her life. We practiced all the things we learned from her therapists at home.

     Again, as a part of early intervention and inclusive schooling/programming, there needs to be support for parent trainings to go with it. The students will not succeed without a strong base at home, in my opinion, which is based on observation.

416. My daughter is 16 years old. We (her family) have worked with her very hard all her life on behavior and speech so that she would be more accepted in the gen.ed. population at school. I have to admit that it was a fight, every single year of her schooling, despite her high abilities, to keep her in an inclusive environment to the level I wanted with the school system. This fight was with teachers, administration and the Spec. Ed. department. She was able to keep up with her peers and is now a sophmore in high school. I have had some teachers (gen.ed.) in every school tell me how much they loved having her in their class and how much they say how her gen.ed. peers loved helping her and having her in class. The teachers thanked ‘me’ for her. When I happen to be in school with her – or out in public, other kids, teachers and parents are alway saying ‘hi’ to her and engaging her in conversation.

     I recently hooked her up with a counselor housed in the high school as I see signs of sadness and/or depression looming as her peers are pulling away from her. I made the comment/thought to the counselor that I wondered if fighting so hard for inclusion would hurt Mary in the long run as kids move on and pull away from her. The counselor has spent some time observing Mary in the school in different classes and settings and has assured me that Mary is very well adjusted – better than some of her ‘typical’ peers who have lessor behavioral and social skills than Mary. She felt Mary has the skills to have a great life and job in the community as an adult, and, that the hard work and skills she gained from her inclusive environment have put her in that position.

     I do not think Mary would be in her current position had she not been allowed to be in an inclusive environment at school. I see other families, not knowing how to help their kids and fight for inclusive rights at school and it breaks my heart that I cannot help them more as I see those children struggling so much in school with on-going behavior issues and poor social skills. It truly takes a ‘community’ to help people with disabilities; locking them in an enclosed environment does not help them in the long run and only promotes bad behaviors.

417. Much of this reads to me as common sense and what all school districts should be doing to support their children.

     An example of an inclusive early childhood program that could serve as a model for this is the Early Childhood Center in Salem, Massachusetts. Our ECC strives for inclusion and is already doing so much of what this statement is calling for.

418. This will be a positive direction to encourage districts to develop and offer inclusive preschool options. Families and children deserve to have these options, given the overwhelming evidence that has shown early inclusive experiences is important for the entire community. Unfortunately, many districts continue to only offer self-contained preschool programs.

419. Our son with Down Syndrome is now 30 years old! Can hardly believe it sometimes! The best intervention he ever received was going to early childhood education classes. He started at 3 weeks of age and continued until entering kindergarten. So much learning potential in those first few years! Before his speech came in they had tought him a few sign language words. Oh the power it gave him to communicate his needs! Not only was Michael challenged to grow but we as parents were given so very many tools to help him succeed. Michael is now an employed, independent and contributing member of society with so much of his success is due to the programs that were available for him when he was young. Early childhood classes for the special needs community is of the utmost importance!

420. The Louisiana Developmental Disabilities Council is encouraged that such a strong policy statement about inclusion of young children with disabilities is being issued. The Council believes that all infants and young children, including those with developmental disabilities, should have access to early intervention services and supports in inclusive environments.

421. Bravo for being proactive in putting out a policy statement for inclusive practices in early childhood. Can’t believe that after 40 years of having a law which clearly says children should be educated in the least restrictive environment we have to have a policy statement. Every child has a right to be with their typical peers in schools and we need to stop the conversation of where a child needs to be located but spend more time about the unique needs the child has and how we are going to provide a good education through quality instruction and making the accommodations and/or modification a child needs rather than spending time where the child is going to be located. I have never understood why schools are so segregated when I don’t see special education malls, churches, etc. It is about time we take additional action as people still do not see IDEA as the catalyst for educating children with their typical peers and siblings. When I read all the comments I am dismayed that the conversation is still about where and not what is good for children. Bravo again for being so proactive. If we would not have pushed inclusive practices for my two sons with disabilities they would not have been as successful as they were and are in the community. High expectations equal high level of competence.

     • Thank you for your comments and love your book

422. As an early childhood research and practice-based agency, the KY Partnership for Early Childhood Services enthusiastically endorses the US DOE Policy Statement on the full inclusion of children with disabilities. Through a variety of state and national initiatives, we have added to the current research literature in documenting the positive impact of inclusion for all young children (http://www.kentuckypartnership.org/Info/Research/Research.aspx). Through our current programs, we support family empowerment, professional development, collaboration, and enhanced intervention strategies as recommended by the DOE Policy Statement.

     The draft policy as written represents a step forward in ensuring children with disabilities receive services in high-quality early childhood programs. We would propose that one area of concern for Kentucky and potentially other states with targeted state-funded preschool services, is the challenge of over-representation of children with disabilities (those with mild to significant disabilities) in these classrooms. While community collaboration and supports to meet the needs of children is mentioned in the Policy Brief, we feel it is critical to recognize that child care centers and family child care homes represent individual businesses. These centers and homes are governed by state regulations, but do not operate as a unit and may not have resources for training and support for highly qualified teachers. To better support these programs and promote more community based opportunities for young children with disabilities, additional emphasis on the importance of state and private partnerships could help address these issues. These partnerships could help ensure children with disabilities are in programs with their typically developing peers, and highly qualified teachers are present in both public and private sectors. While the policy has been written in such a way to include private child care partners, providing more explicit recommendation, such as public/private partnerships could help move us forward in supporting more inclusive settings. As the policy intended and the KY Partnership Services highlight, an emphasis on blending services will benefit all children.

423. As a mother of two young children, I am in full support of an inclusion based program. My oldest, a typically developing child, was part of an inclusion based preschool. The program allows him to better understand the many differences of students and gain an acceptance of children of all abilities. We have had several very encouraging and educational discussions about why a child may be in a wheelchair or act a certain way. He doesn’t know his brother has Down Syndrome and may be considered different from other kids, because, with an all inclusive program he has peers in his class that have Down Syndrome as well. Those peers are just like him! There is so much bullying and misunderstanding of children with disabilities in school, I personally believe an inclusive program helps minimize the differences. Those children that are exposed to kids with disabilities just see the kids for themselves as a peer because they have played together, learned together, just been kids together.

     For my Special Needs child, I want my student to be included with his peers. Early childhood Special Education students need to see and hear their peers model appropriate playing, language skills, and learning. They needs to be with the kids within their community and to form those bonds and understanding that people with disabilities are not limited in their achievements.

     Over the past decade, look how much has already been achieved for people with disabilities. No longer are parents encouraged to abandon their children and send them away. People with disabilities are thriving. Can you imagine how much more can be achieved with the start of inclusion-based early childhood education? I see a promising future and nation!

424. Inclusion is not necessarily the Least Restrictive Environment. Disabled students placed in an inclusion classroom may not receive the support they need.

     • Least Restrictive Environments may also be a challenge for a disabled student(s) their peers and for the extended family members of the graduating classroom. Middle school can be different.

425. I fully support inclusive environments, when appropriate supports and services are provided. I know it can work. However, I believe that the Federal government needs to turn this problem over to the states and allow far more local control, so that a variety of agencies can work together without the restrictions caused by a variety of rules and laws and accountability that may not be appropriate for a given school district or community. Additionally, I have great concerns that many children who live in poverty or impoverished language environments, are “labeled” as special needs when in fact, they are lacking exposure and experiences. These kids are easily mislabeled and place huge burdens on already taxed services of SLP’s and OT’s when they actually need a high quality early childhood setting and parental training on how to talk to and interact with their kids. When using our current “objective measures” many of these children are eligible for Early Intervention or special education services but are they really handicapped, or do they need language and environmental stimulation? (and not I-pads and other technology)
     With a poverty rate of nearly 50% in this country, this is an area that needs to be addressed as part of this issue. Not all children living in poverty are language or developmentally delayed, however, many are according to current research.
     It would be great if states considered a school curriculum policy that would include the importance of teaching our youth (as potential parents), beginning at middle school, about the importance of “talking to their children” and recognizing that if they bring these little ones into the world, they need to participate in their learning and development. We need to start early with our youth so that they truly see that they really are “their children’s first teachers” and how important their input is to their children’s development. The science in this area is very clear.
     When students learned about the importance of recycling in elementary school, they began to recycle and put pressure on their parents to do so. When children went to preschool and their teachers stressed the importance of wearing a seat belt when riding in a car, they were more willing to do so and put pressure on their parents to wear their seat belts. When important information is presented to children at an early age, they often embrace it. It seems that this approach might also work in the area of teaching potential parents about how to nurture and facilitate their own child’s development, so that more children can come to school “ready to learn”. Talking to your kid doesn’t cost any money, but if done correctly, can have huge payoffs. We need to teach this to our youth, early and often. We could avoid many, many children starting school nearly two years behind their peers, whose parents do “talk to them”.

426. As an educator and parent , I whole-heartedly support inclusive education. Our daughter, who has a diagnosis of Down syndrome and is now approaching her third birthday, has been in an inclusive environment for the past two years. My husband and I had to fight to get this, and we are grateful every day that we did. She is thriving, and so are her peers. The children all learn from each other. Our daughter has met many milestones earlier than her same-aged peers with Ds in our community, but even if she hadn’t, inclusion is the best path for our family. We firmly believe her successes have more to do with her educational environment and personality than other factors. Had she been in an environment with predominantly children with disabilities, she would have likely acquired behaviors we are trying to avoid. The way we have it, she is walking, talking, eating, potty-training, and participating in the world along with her same-aged peers.
     As NDSS has submitted, please change of the definition of “regular early childhood program” from 50% SWDs to 10-12%, which better reflects the world my daughter lives in.
     This policy is not only beneficial to children with disabilities, but those who do not have diagnoses. The typically-developing children in my daughter’s class have increased awareness and empathy. Hard to measure, to be sure, but they are on the road to being adults whose experience includes, instead of excludes their peers.

     Thank you for including all children in this definition. Any child with any level of disability can be included. Support for the classroom teacher and training for all staff is key, but this policy statement is a step in the right direction.

427. As the representative of organizations concerned with provision of transition services on the Kansas Special Education Advisory Council (SEAC), and having read the May 15, 2015, Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs, I endorse the shared vision of the U.S. Department of Health and Human Services and the U.S. Department of Education as it is expressed in that document. (I do note a minor typo in the next to last paragraph on page 5, where there is an extraneous article “a” preceding a plural noun phrase.)

     I suggest that an effective way to start transitioning public spaces and raising awareness of universal access in communities across the state of Kansas would be to join local partners to Play Core, or a similar accessible playground provider, to bring children, families, and professionals together around inclusive outdoor activities, aligned with architectural universal design principles applied to playground construction. The Play Core design principles, developed at Utah State University’s Center for Persons with Disabilities and aligned to traditional universal design principles, are: 1) Be fair/equitable use; 2) Be included/flexibility in use; 3) Be smart/simple and intuitive use; 4) Be independent/perceptible information; 5) Be safe/tolerance for error; 6) Be active/low physical effort; 7) Be comfortable/size and space for approach and use. PlayCore offers partial matching grants, and any community seeing these inclusive playgrounds appearing at public schools and in city parks would naturally be encouraged to engage in the kinds of conversations that build awareness and start the important transition process of public spaces that will impact early childhood practices as well as inclusive approaches to schooling and lifelong access to public activity for all community members. These open access playgrounds would also be wonderful additions to Child Find activities, a key to assessing and meeting the needs of children with developmental delays and disabilities and their families. As special education teacher educator and an advocate for culturally responsive post-secondary transition outcomes, I heartily embrace the Draft Policy’s vision, “that all children have access to inclusive high-quality early childhood programs [with] shared responsibility and commitment within communities, strong state and local leadership, and a robust partnership between families, schools, communities, and government at all levels.” New, inclusive playgrounds would be a wonderful visual symbol of these changes, and centers for the trainings and conversations that will have to happen if inclusive policies are to become reality.
     Sincerely, – Robert Bruce Scott, Ed.D., Founder/Director of Kansans for Equal Access to Transition Services (keatsks.org).

428. I cannot begin to express the importance of inclusion. Moving our Daughter from a specialized classroom to a Public school environment with inclusion has helped her thrive. Watching her typical peers interact with her, ask questions, and simply accepting her is such a positive experience for everyone. They will grow up to be more empathetic and understanding of those with disabilities. Our Daughter started the beginning of the year basically being non verbal, with very little self-help skills, but through peer modeling she has improved so much! She is being challenged on an educational level which will help her build a solid foundation that will help her succeed through HS and College. It needs to begin early, not later, the future for our children starts now.

429. There should not be a policy on inclusion. We should follow the law. In the ideal all children should be educated together but school districts “go cheap” and do not provide all of the support services that are needed. Specialized private schools develop these children to their greatest potential and are cost effective when considering the long term cost of unionized public workers and facilities.

430. The American Society for Deaf Children (ASDC) is a national, non-profit organization that provides information, support and encouragement to families. ASDC was founded in 1967 and continues to empower families to create opportunities for their deaf children to gain meaningful communication access in their home, school and community.
     The American Society for Deaf Children does not support this policy statement on inclusion of children with disabilities. ASDC feels that there are serious flaws and deficiencies in this document. This document disregards the individualized nature of the Individuals with Disabilities Education Act (IDEA) and assumes that the general education environment can appropriately serve all students.
     The word “inclusion” does not appear in IDEA and is not mandated by IDEA. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be evaluated by qualified evaluators; the IEP team, which includes the parents, develop goals for the child, based on those needs; a description of services necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on the above steps. This document focuses on “inclusion” without addressing the steps necessary to determine an appropriate placement for the child.
     IDEA requires public agencies provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.
     This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child. The U.S. Department of Education has stated “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.”
     Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers.
     ASDC believes this policy statement is NOT needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

431. As a father of a 16 month old with Downs my son would find inclusion extremely beneficial to his future. He currently has 3 special education sessions a week that help him tremendously, and us as the parents learning what he needs to learn regarding his disability.
     Per the National Downs Syndrome Congress:
     •Currently an early childhood setting is counted as a regular early childhood program if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (approximately 10-12%) is considered “a regular early childhood program.” This change is consistent with the recommendations in the policy statement.
     •Currently the OSEP data collection does not distinguish between a child attending a regular education early childhood program that is provided by the school district (in either a public or private setting) and one that is provided by the parents. In order to ensure transparency as to the district’s role, the data collection should be changed to reflect this important distinction.
     Thank you

432. Therefore, while this drafted policy brilliantly outlines early childhood education programs’ obligations, I believe the family engagement piece needs to be more robust.

     a) Hold early childhood education programs directly accountable. Thomas Jefferson University has a program called Philadelphia Inclusion Network (PIN), which has done trainings for early childhood education providers for years. What if the federal government provided funds to states toward the creation an online directory of early childhood education providers who have undergone training on inclusion? The online directory should have a rating mechanism so families can leave reviews about their child’s inclusion in the early childhood education program. Providers that post non-discrimination statements and go through great lengths to receive accreditation, only to knowingly violate ADA and IDEA, would finally be held accountable.

     b) Require language access plans in family engagement efforts. The U. S. Department of Health and Human Services, with its Office of Minority Health, developed national standards for Culturally and Linguistically Appropriate Services (CLAS) to assure that all individuals regardless of their background or culture have access to quality health care. When it comes to serving children with disabilities, I believe the same principles need to apply to early childhood education. When I talk to immigrant parents, they cannot read therapy notes written in English, nor are they aware that they have a right to an interpreter for IEP meetings. The reality is that these families have a right to interpreters and translated documents. I am working with Pennsylvania Office of Child Development and Early Learning and Pennsylvania Training and Technical Assistance Network to develop family’s rights materials in plain language, and to bring that information in various formats to the grassroots. This should be happening across the country.

     c) Assess the efficacy of current family engagement efforts and develop metrics for inclusion of the family in the education of their child. It is clear to me that some early childhood education programs take a paternalistic attitude toward parents of children with disabilities, assuming that parents or grandparents are too ignorant to be experts on their children’s educational needs, or that immigrant parents or grandparents in particular will not be interested in learning how to therapeutic strategies to be carried out at home. It is not enough for early childhood education providers develop workshops to satisfy a family engagement component for accreditation. There should be a feedback mechanism for families to share how they were treated during IEP/IFSP meetings, and whether they felt respected as equals on the IEP/IFSP team.

     d) Develop a pipeline for culturally and linguistically competent interpreters and providers. Temple Institute on Disabilities has a long-running program in which parents are trained and paid to provide interpretation services to other families. That is one important crucial to empowering families to be a part of the IEP/IFSP team. I believe another step is to make job descriptions for therapists available in multiple languages, create job opportunities in underserved communities by recruiting diverse individuals to train as early childhood education providers and early intervention therapists, so that families in those communities can select more culturally and linguistically appropriate providers.

433. I’m the mother of two young children on the autism spectrum. I am an active volunteer in my community here in Philadelphia. Recently, I began to partner with local agencies and Early Intervention providers to help them develop culturally and linguistically appropriate resources for undeserved communities. I wanted to share with you my experiences as a parent who is currently navigating this system.

     First, I want to commend U.S. Departments of Education and Health and Human Services for drafting this important policy and clarifying the obligations of early childhood education providers under IDEA and the Americans with Disabilities Act and the Rehabilitation Act (Sec. 504). As a mother who has searched for appropriate early childhood education providers, I have stopped counting the number of times that I or other parents called an early childhood education provider to inquire about their programs, and received the following responses:

     • “Is your child low functioning or high functioning?”
     • “Is your verbal or non-verbal?”
     • “Does your child get services? Will she or he come with an aide?”
     • “Does your child have behaviors? Is he or she aggressive?”

     For early childhood education providers, these may be initial “fact-finding” questions, but they are glaring indications that the early childhood education provider isn’t yet prepared to include a child requiring moderate or significant support in their current program. The CDC estimates that 1 in 68 children have been identified as being on the autism spectrum. It’s time for early childhood programs to be prepared to include the entire spectrum.

     Inevitably, during those initial calls to early childhood education providers, there is always one question that screens children with delays out, “Is your child potty-trained?” When a parent says no, the response is usually, “Oh, I’m sorry. Our preschool program doesn’t accept children still in diapers. Our facilities just aren’t equipped for that.” If the provider is sympathetic to the parent, he or she may even suggest, “However, you may enroll your four year-old in our (usually more expensive) toddler daycare program, which consists of two and three year-olds… but I know that’s not what you’re looking for. Sorry we don’t have anything for you. Good luck!”

     Aside from the fact that in a truly inclusive society, an early childhood education provider would offer a disability accommodation or to add toilet training to the IEP, if appropriate, to support the child’s full inclusion in the preschool program, when a provider recommends placing a preschool-aged child on the spectrum in a program with two and three year-olds due to his or her toileting readiness, it suggests that the provider believes the child with disability is in need of daycare, but not a preschool education. Moreover, it would seem that the provider erroneously believes that a child’s abilities determine his or her “mental age.” Children with disabilities should be offered placements with their peers, not automatically assumed to be a better fit for children half their age.

     Sadly, the questions and comments above have been made to me by early childhood education providers with non-discrimination statements on their websites and colorful brochures featuring racially diverse children. These are providers who consider themselves to be good people, good boards, and good general counsel. Yet, sometimes I wonder whether they realize that ADA and IDEA are more than marketing gimmicks: these laws are intended to protect the rights of children like mine. I’m grateful to the Obama Administration for taking a bold step in clarifying early childhood education providers’ obligations to children with disabilities.

     (continued)

434. I’m the mother of two young children on the autism spectrum. I am an active volunteer in my community here in Philadelphia. Recently, I began to partner with local agencies and Early Intervention providers to help them develop culturally and linguistically appropriate resources for undeserved communities. I wanted to share with you my experiences as a parent who is currently navigating this system.

     First, I want to commend U.S. Departments of Education and Health and Human Services for drafting this important policy and clarifying the obligations of early childhood education providers under IDEA and the Americans with Disabilities Act and the Rehabilitation Act (Sec. 504). As a mother who has searched for appropriate early childhood education providers, I have stopped counting the number of times that I or other parents called an early childhood education provider to inquire about their programs, and received the following responses:

     • “Is your child low functioning or high functioning?”
     • “Is your verbal or non-verbal?”
     • “Does your child get services? Will she or he come with an aide?”
     • “Does your child have behaviors? Is he or she aggressive?”

     For early childhood education providers, these may be initial “fact-finding” questions, but they are glaring indications that the early childhood education provider isn’t yet prepared to include a child requiring moderate or significant support in their current program. The CDC estimates that 1 in 68 children have been identified as being on the autism spectrum. It’s time for early childhood programs to be prepared to include the entire spectrum.

     Inevitably, during those initial calls to early childhood education providers, there is always one question that screens children with delays out, “Is your child potty-trained?” When a parent says no, the response is usually, “Oh, I’m sorry. Our preschool program doesn’t accept children still in diapers. Our facilities just aren’t equipped for that.” If the provider is sympathetic to the parent, he or she may even suggest, “However, you may enroll your four year-old in our (usually more expensive) toddler daycare program, which consists of two and three year-olds… but I know that’s not what you’re looking for. Sorry we don’t have anything for you. Good luck!”

     Aside from the fact that in a truly inclusive society, an early childhood education provider would offer a disability accommodation or to add toilet training to the IEP, if appropriate, to support the child’s full inclusion in the preschool program, when a provider recommends placing a preschool-aged child on the spectrum in a program with two and three year-olds due to his or her toileting readiness, it suggests that the provider believes the child with disability is in need of daycare, but not a preschool education. Moreover, it would seem that the provider erroneously believes that a child’s abilities determine his or her “mental age.” Children with disabilities should be offered placements with their peers, not automatically assumed to be a better fit for children half their age.

     Sadly, the questions and comments above have been made to me by early childhood education providers with non-discrimination statements on their websites and colorful brochures featuring racially diverse children. These are providers who consider themselves to be good people, good boards, and good general counsel. Yet, sometimes I wonder whether they realize that ADA and IDEA are more than marketing gimmicks: these laws are intended to protect the rights of children like mine. I’m grateful to the Obama Administration for taking a bold step in clarifying early childhood education providers’ obligations to children with disabilities.

     When we are talking about what it takes to provide children with disabilities with high-quality early childhood education, I believe our federal government needs to examine the licensing ratios for day cares and early childhood education programs across the country. In Pennsylvania, the ratio for a preschool class is 20 children to two adults. The children range from ages 3-5, whose needs may range from socialization needs to kindergarten preparedness. When you add children with disabilities, two teachers are not enough to support the incredible range of needs in a classroom of 20 preschoolers. The sheer size and age range of typical preschools, particularly in urban areas like Philadelphia, make quality instruction extremely challenging even for the most bright and caring teachers. To make matters worse, my son’s teachers were usually out of the classroom for Head Start home visits, parent teacher meetings, staff meetings, conferences, and teacher planning. Year-round, substitutes were in the classroom morning and/or afternoon, which made it extremely difficult for there to be any consistent instruction. Even when there were wonderful, caring substitutes, the early childhood education program could not afford to schedule them regularly and therefore there was frequent staff turnover. When new adults were frequently shuffled into classrooms in order to meet Pennsylvania code for student to adult ratios, it was doubtful whether those adult read any students’ IEPs/IFSPs and/or have received proper training about inclusion, ADA, IDEA, English Language Learners, or their students’ disabilities. I invite policy makers to spend a day in a Head Start or urban preschool teacher’s shoes: attempt to teach a class of 20 preschoolers, with varying abilities and needs, in the limited amount of time you have in the classroom, while balancing other program obligations and a second job since Head Start doesn’t compensate well. Teachers, substitute teachers, and staff employed through Head Start (or similar programs) deserve better compensation to prevent staff turnover. Children with disabilities need consistency in their teachers. They need experienced teachers. They need teachers who are present to implement the IEP/IFSP. If you can increase the funding for teachers and staff employed through Head Start, you can help ensure that children with disabilities will have better quality instruction.

     (continued)

     • Funding and program issues aside, across parenting message boards, there is a consistent theme that some early childhood education providers believe the inclusion of our children is a charitable act by the program, and not our children’s right under IDEA and ADA. In my experience, our IEP team tried very hard to communicate that philosophically, my son was to be educated in the least restrictive environment in his community with his peers. We believed the role of therapists was to share strategies with the school, for the school to learn how to teach to my child, for my child to be able to participate in the program as successfully as possible, and eventually to fade out supports when he was ready. Yet, it was evident to me through therapy session notes that in practice, when my son’s therapists arrived, he became their student, who happened to be receiving his services in a typical preschool classroom. When our IEP team made suggestions for modifications to teaching strategies or (God forbid) blanket rules prohibiting disability accommodations, the school was very set in their beliefs, which unfortunately predated the existence of IDEA and all the current research about autism. I think the culture of schools must change to respect the expertise of direct therapy providers and families.

       Ultimately, when our IEP team requested a more appropriate placement for the next academic year, citing issues with the curriculum, the early childhood education provider initially agreed to permit our IEP team to observe a classroom with a different curriculum. However, the visits never happened and the early childhood education provider informed us that we needed to make a decision immediately about whether we would remain in the current classroom. In other words, they were not going to give us a choice of classrooms. We chose to leave the program, as it was clear that they were no longer interested in supporting my son’s education. That is how I learned that even a highly lauded early childhood education program accredited by National Association for the Education of Young Children can completely fail to understand the basic principles behind IDEA and ADA. The only recourse that I had was to file civil rights complaints with the appropriate agencies.

       When parents of typically developing children tell me they have gone through four preschool or daycare providers before finding a good fit, I despair that families like mine must consider early childhood education providers well outside of our communities and outside of our budgets. The search for an appropriate, inclusive provider is a drain on time, money, and resources. Computer literate parents may resort to contacting parent listservs, asking for other families’ recommendations. However, as any parent reading this comment knows, a welcoming program can turn into a bad program with the departure of a specific teacher, a program administrator, or the director. Programs can and do change year to year. Therefore, word-of-mouth isn’t even reliable. While early intervention providers are rightfully expected to empower families when they identify problems with programs, the reality is therapy providers and individual contractors must remain on civil terms with agencies and early childhood education programs. Fear of retribution or lack of knowledge about how to report discrimination are real barriers.

       Therefore, while this drafted policy brilliantly outlines early childhood education programs’ obligations, I believe the family engagement piece needs to be more robust.

       a) Hold early childhood education programs directly accountable. Thomas Jefferson University has a program called Philadelphia Inclusion Network (PIN), which has done trainings for early childhood education providers for years. What if the federal government provided funds to states toward the creation an online directory of early childhood education providers who have undergone training on inclusion? The online directory should have a rating mechanism so families can leave reviews about their child’s inclusion in the early childhood education program. Providers that post non-discrimination statements and go through great lengths to receive accreditation, only to knowingly violate ADA and IDEA, would finally be held accountable.

       b) Require language access plans in family engagement efforts. The U. S. Department of Health and Human Services, with its Office of Minority Health, developed national standards for Culturally and Linguistically Appropriate Services (CLAS) to assure that all individuals regardless of their background or culture have access to quality health care. When it comes to serving children with disabilities, I believe the same principles need to apply to early childhood education. When I talk to immigrant parents, they cannot read therapy notes written in English, nor are they aware that they have a right to an interpreter for IEP meetings. The reality is that these families have a right to interpreters and translated documents. I am working with Pennsylvania Office of Child Development and Early Learning and Pennsylvania Training and Technical Assistance Network to develop family’s rights materials in plain language, and to bring that information in various formats to the grassroots. This should be happening across the country.

       c) Assess the efficacy of current family engagement efforts and develop metrics for inclusion of the family in the education of their child. It is clear to me that some early childhood education programs take a paternalistic attitude toward parents of children with disabilities, assuming that parents or grandparents are too ignorant to be experts on their children’s educational needs, or that immigrant parents or grandparents in particular will not be interested in learning how to therapeutic strategies to be carried out at home. It is not enough for early childhood education providers develop workshops to satisfy a family engagement component for accreditation. There should be a feedback mechanism for families to share how they were treated during IEP/IFSP meetings, and whether they felt respected as equals on the IEP/IFSP team.

       d) Develop a pipeline for culturally and linguistically competent interpreters and providers. Temple Institute on Disabilities has a long-running program in which parents are trained and paid to provide interpretation services to other families. That is one important crucial to empowering families to be a part of the IEP/IFSP team. I believe another step is to make job descriptions for therapists available in multiple languages, create job opportunities in underserved communities by recruiting diverse individuals to train as early childhood education providers and early intervention therapists, so that families in those communities can select more culturally and linguistically appropriate providers.

       Thank you for your consideration.

435. I fully support this policy to encourage high quality inclusive preschool settings for children with disabilities. My son is 6 yrs with Down syndrome and our county in Virginia does not offer inclusive preschool options. The only option is a self contained model. We chose to go to a private preschool that we paid for so our son could have an inclusive experience. Our son thrived in that environment and I believe it’s the key reason as to why he is doing so well in his now inclusive K public school classroom. We did choose one year of the self contained model for two days per week and while he received the special education services from a well qualified special educator, he was surrounded by other children with learning, speech and behavior issues that did not provide models to allow him to improve. He did not enjoy that class and much preferred the inclusive private preschool days. I believe that parents are at the mercy of the school system for these preschool years. The early childhood process is a parents first introduction to the school system, the parent deals with it on a district level versus a individual school level and a parent is only in that system for two years before moving to Kindergarten. This allows for limited parent advocacy for system change since by the time they have figured out the segregated preschool options they are off advocated for inclusion in elementary school. Pleaee continue to support the local school systems with this policy and the program’s necessary to help them overcome the challenges associated with its implementation. Thank you.

436. I have a granddaughter with Down syndrome. I am also a volunteer in one of Virginia’s Human Rights committees. These experiences have taught me that inclusion of people with developmental disabilities in all types of programs is a critical component of education and life satisfaction not only for those with disabilities, but also for the general population.

437. I’d like to thank the Department for the efforts in addressing inclusive practices for the youngest of our citizens with disabilities through this policy summary. I appreciate that Part C was included in the summary as well as some of our most important partners, Head Start and Child Care Block Grant.

     I have a 16 year old daughter who was in Part C almost on Day 1 of her life due to her prenatal diagnosis of Down syndrome. Inclusive practices along the way have made her into the confident and competent young lady that she is today and I am eternally grateful for the pioneers of IDEA and all that it has to offer.

     I do believe that the work needs to continue and Early Childhood seems to be one area where we can work together to make these efforts more evident. One of the areas that continues to be problematic is maintaining a stable and predictable setting for preschoolers without major disruptions. Because special education services are often delivered in different settings, a child’s and parents’ days are often broken up. Nap times are disrupted. Parents have to figure out transportation at times they should be at work. Children have to navigate many different caregivers. Communication regarding supports and goals are difficult to exchange and incorporate across settings. Child care settings go without professional consultation. We have to figure out how to fix this with more imbedded approaches and less bricks and mortar for separate special education classrooms.

     More specifically in reference to the policy summary, I’d like to offer a few suggestions:
     State Recommendations #1 – I would like to see the policy summary specifically reference the State Interagency Coordinating Councils and the State Advisory Panels. The partners that you have listed in the summary are already included (required) on these 2 statewide committees as well as included in states’ Early Childhood Councils. We need to assure that states are not required to create a new task force, but utilizing what is already in place. I would just assure that you make implications to include family support organizations and the state PTI.

     State Recommendations #9: State lawmakers are going to be an essential audience in assuring that these supports get implemented in an effective manner – I’d suggest adding them to this section.

     Early Childhood Recommendation #1: I’d suggest specifically including a discussion about using the support of the state PTI in partnering with families.

     Early Childhood Recommendation #7: I’d like to recommend that this section be broadened to include supports that are not just delivered by professionals, such as assistive technology, adaptive equipment, and accommodations. One of the concerns that I have for Early Childhood is that we are very often fixated on “changing” the child vs. accommodating their environment to meet their needs. We get better at that as they age, but early on, we are very concerned about their developmental milestones. While we need to keep an eye on meeting their developmental needs, we also have to think about what their peers without disabilities are doing and how we can help them do those same types of activities. Often times too much time is spent with professionals and not enough time doing the kinds of things that little kids do every day. I’d also like to see this section broadened to include the family support components that are so essential and so again, I would urge you to discuss the partners such as PTI’s and other family based, family support organizations that help families navigate the system. We tend to be very good about supporting our families up through Part C and then this becomes more disjointed once children turn 3.

     Again thank you for your attention to this very important topic.

     Early Childhood Recommendations #1 –

438. I am so pleased to see a a concise definition and expectation for inclusion in the early childhood setting. High quality childcare has always been a challenge for my three children on the autism spectrum. It was not for lack of available options; it was always about staff perceptions and training. We must get back to the fundamental idea that just because a child has a challenge does not mean they can not be included.

439. I wholeheartedly support this much-needed recommendation! I am the parent of a young woman with significant intellectual disabilities who just graduated high school after being successfully included her entire school career. My daughter was included in preschool, which gave her the skills she needed to be successful in an inclusive Kindergarten.

     It is interesting to note that most of the non-supportive comments posted here mention the lack of services or students sitting at the back of the room. Throwing students with disabilities into a classroom without bringing along the supports is not inclusion. We would not think of putting students with disabilities into a special class without supports being provided in that classroom – why would we consider doing that in general education? It is important to remember that “Special Education is a service, not a place.”
     I am also pleased that this statement specifically mentions students with significant disabilities. Oftentimes, school districts support inclusion or other initiatives for students with mild disabilities, but continue to exclude those with more significant disabilities.

440. As an educator and early childhood advocate, I strive to promote exceptional education and resources to all families of young children – especially those whom have special needs. Promoting inclusion at an early age sets the tone for the rest of the child’s educational career. It benefits the child in so many obvious aspects but also teaches all children awareness and acceptance. I have personally seen great community collaboration within the early childhood classrooms when all are accepted.
     Being a parent of a special needs child who is going through the school system, I see her as an accepted and valued individual by her peers. This can only be that she has been with them since she was in early childhood.
     There are so many high quality programs out there- every child needs to have the opportunity to grow.

441. As a supporter of inclusiveness in our schools and in our community, I believe it is imperative that the law fully support inclusion. While IDEA DOES make note of the least restrictive environment, it does NOT clarify inclusion specifically. That needs to change. There is no scientific data against inclusion, its all in favor of inclusion because it benefits everyone not just the young child with a disabling condition, but also the students considered “typical”. My hope is that during my lifetime we will have made laws that prohibit ANY type of stigma, stereotype and segregation.

442. Education is only a part of lives as a whole. When people are separated because of differences we lose our sense of togetherness. After all we are human with flaws and imperfections that let us know who we are or aren’t. The Human race isn’t designed for facially recognized beings as a way to define us not does it pretend to give way to our inner and outer mind and function. We are educated to help us grow in quality and virtue of human life without limited freedom. Rights for all people are required to give us this pride and dignity as a way of truly educating our mindset of this world. Inclusion in all and through all our lifetime is a must.

443. As a parent to a child with Down syndrome, I fully support this policy. We are troubled by the issues our 5 year old has encountered in our public school system. During IEPs, the LRE was determined to be a special education class with inclusion volunteered by local children who would sit in the class periodically if the teacher decided to look for such peer models. This is unacceptable. Our daughter is delayed in speech, and because of that they wouldn’t even allow the chance for her to be in a general education classroom. The IEP “team” decided for us and listened to our ideas and desires but refused to implement them because they felt the LRE was a special education class. It is high time these things change and that schools and school systems are brought up to speed on RECENT developments and studies on children with disabilities in true LREs and allowed to be included.

444. just as the earlier a second language is taught the more a child can easily learn it, the same is true with inclusion.
     Inclusion starts at birth and a child not included with their peers from the beginning is not as easily included later on.

445. My name is Anna Perng. I’m the mother of two young children on the autism spectrum. I am an active volunteer in my community here in Philadelphia. Recently, I began to partner with local agencies and Early Intervention providers to help them develop culturally and linguistically appropriate resources for undeserved communities. I wanted to share with you my experiences as a parent who is currently navigating this system.

     First, I want to commend U.S. Departments of Education and Health and Human Services for drafting this important policy and clarifying the obligations of early childhood education providers under IDEA and the Americans with Disabilities Act and the Rehabilitation Act (Sec. 504). As a mother who has searched for appropriate early childhood education providers, I have stopped counting the number of times that I or other parents called an early childhood education provider to inquire about their programs, and received the following responses:

     • “Is your child low functioning or high functioning?”
     • “Is your verbal or non-verbal?”
     • “Does your child get services? Will she or he come with an aide?”
     • “Does your child have behaviors? Is he or she aggressive?”

     For early childhood education providers, these may be initial “fact-finding” questions, but they are glaring indications that the early childhood education provider isn’t yet prepared to include a child requiring moderate or significant support in their current program. The CDC estimates that 1 in 68 children have been identified as being on the autism spectrum. It’s time for early childhood programs to be prepared to include the entire spectrum.

     Inevitably, during those initial calls to early childhood education providers, there is always one question that screens children with delays out, “Is your child potty-trained?” When a parent says no, the response is usually, “Oh, I’m sorry. Our preschool program doesn’t accept children still in diapers. Our facilities just aren’t equipped for that.” If the provider is sympathetic to the parent, he or she may even suggest, “However, you may enroll your four year-old in our (usually more expensive) toddler daycare program, which consists of two and three year-olds… but I know that’s not what you’re looking for. Sorry we don’t have anything for you. Good luck!”

     Aside from the fact that in a truly inclusive society, an early childhood education provider would offer to make a disability accommodation or add toilet training to the IEP, if appropriate, to support the child’s full inclusion in the preschool program, when a provider recommends placing a preschool-aged child on the spectrum in a program with two and three year-olds due to his or her toileting readiness, it suggests that the provider believes the child with disability is in need of daycare, but not a preschool education. Moreover, it would seem that the provider erroneously believes that a child’s abilities determine his or her “mental age.” Children with disabilities should be offered placements with their peers, not automatically assumed to be a better fit for children half their age.

     Sadly, the questions and comments above have been made to me by early childhood education providers with non-discrimination statements on their websites and colorful brochures featuring racially diverse children. These are providers who consider themselves to be good people, good boards, and good general counsel. Yet, sometimes I wonder whether they realize that ADA and IDEA are more than marketing gimmicks: these laws are intended to protect the rights of children like mine. I’m grateful to the Obama Administration for taking a bold step in clarifying early childhood education providers’ obligations to children with disabilities.

     When we are talking about what it takes to provide children with disabilities with high-quality early childhood education, I believe our federal government needs to examine the licensing ratios for day cares and early childhood education programs across the country. In Pennsylvania, the ratio for a preschool class is 20 children to two adults. The children range from ages 3-5, whose needs may range from socialization needs to kindergarten preparedness. When you add children with disabilities, two teachers are not enough to support the incredible range of needs in a classroom of 20 preschoolers. The sheer size and age range of typical preschools, particularly in urban areas like Philadelphia, make quality instruction extremely challenging even for the most bright and caring teachers. To make matters worse, my son’s teachers were usually out of the classroom for home visits, parent teacher meetings, staff meetings, conferences, and teacher planning. Year-round, substitutes were in the classroom morning and/or afternoon, which made it extremely difficult for there to be any consistent instruction. Even when there were wonderful, caring substitutes, the early childhood education program could not afford to schedule them regularly and therefore there was frequent staff turnover. When new adults were frequently shuffled into classrooms in order to meet Pennsylvania code for student to adult ratios, it was doubtful whether those adult read any students’ IEPs/IFSPs and/or have received proper training about inclusion, ADA, IDEA, English Language Learners, or their students’ disabilities. I invite policy makers to spend a day in a Head Start or urban preschool teacher’s shoes: attempt to teach a class of 20 preschoolers, with varying abilities and needs, in the limited amount of time you have in the classroom, while balancing other program obligations and a second job since Head Start doesn’t compensate well. Teachers, substitute teachers, and staff employed through Head Start (or similar programs) deserve better compensation to prevent staff turnover. Children with disabilities need consistency in their teachers. They need experienced teachers. They need teachers who are present to implement the IEP/IFSP. If you can increase the funding for teachers and staff employed through Head Start, you can help ensure that children with disabilities will have better quality instruction.

     Funding and program issues aside, across parenting message boards, there is a consistent theme that some early childhood education providers believe the inclusion of our children is a charitable act by the program, and not our children’s right under IDEA and ADA. In my experience, our IEP team tried very hard to communicate that philosophically, my son was to be educated in the least restrictive environment in his community with his peers. We believed the role of therapists was to share strategies with the school, for the school to learn how to teach to my child, for my child to be able to participate in the program as successfully as possible, and eventually to fade out supports when he was ready. Yet, it was evident to me through therapy session notes that in practice, when my son’s therapists arrived, he became their student, who happened to be receiving his services in a typical preschool classroom. When our IEP team made suggestions for modifications to teaching strategies or (God forbid) blanket rules prohibiting disability accommodations, the school was very set in their beliefs, which unfortunately predated the existence of IDEA and all the current research about autism. I think the culture of schools must change to respect the expertise of direct therapy providers and families.

     Ultimately, when our IEP team requested a more appropriate placement for the next academic year, citing issues with the curriculum, the early childhood education provider initially agreed to permit our IEP team to observe a classroom with a different curriculum. However, the visits never happened and the early childhood education provider informed us that we needed to make a decision immediately about whether we would remain in the current classroom. In other words, they were not going to give us a choice of classrooms. We chose to leave the program, as it was clear that they were no longer interested in supporting my son’s education. That is how I learned that even a highly lauded early childhood education program accredited by National Association for the Education of Young Children can completely fail to understand the basic principles behind IDEA and ADA. The only recourse that I had was to file civil rights complaints with the appropriate agencies.

     When parents of typically developing children tell me they have gone through four preschool or daycare providers before finding a good fit, I despair that families like mine must consider early childhood education providers well outside of our communities and outside of our budgets. The search for an appropriate, inclusive provider is a drain on time, money, and resources. Computer literate parents may resort to contacting parent listservs, asking for other families’ recommendations. However, as any parent reading this comment knows, a welcoming program can turn into a bad program with the departure of a specific teacher, a program administrator, or the director. Programs can and do change year to year. Therefore, word-of-mouth isn’t even reliable. While early intervention providers are rightfully expected to empower families when they identify problems with programs, the reality is therapy providers and individual contractors must remain on civil terms with agencies and early childhood education programs. Fear of retribution or lack of knowledge about how to report discrimination are real barriers.

     Therefore, while this drafted policy brilliantly outlines early childhood education programs’ obligations, I believe the family engagement piece needs to be more robust.

     a) Hold early childhood education programs directly accountable. Thomas Jefferson University has a program called Philadelphia Inclusion Network (PIN), which has done trainings for early childhood education providers for years. What if the federal government provided funds to states toward the creation an online directory of early childhood education providers who have undergone training on inclusion? The online directory should have a rating mechanism so families can leave reviews about their child’s inclusion in the early childhood education program. Providers that post non-discrimination statements and go through great lengths to receive accreditation, only to knowingly violate ADA and IDEA, would finally be held accountable.

     b) Require language access plans in family engagement efforts. The U. S. Department of Health and Human Services, with its Office of Minority Health, developed national standards for Culturally and Linguistically Appropriate Services (CLAS) to assure that all individuals regardless of their background or culture have access to quality health care. When it comes to serving children with disabilities, I believe the same principles need to apply to early childhood education. When I talk to immigrant parents, they cannot read therapy notes written in English, nor are they aware that they have a right to an interpreter for IEP meetings. The reality is that these families have a right to interpreters and translated documents. I am working with Pennsylvania Office of Child Development and Early Learning and Pennsylvania Training and Technical Assistance Network to develop family’s rights materials in plain language, and to bring that information in various formats to the grassroots. This should be happening across the country.

     c) Assess the efficacy of current family engagement efforts and develop metrics for inclusion of the family in the education of their child. It is clear to me that some early childhood education programs take a paternalistic attitude toward parents of children with disabilities, assuming that parents or grandparents are too ignorant to be experts on their children’s educational needs, or that immigrant parents or grandparents in particular will not be interested in learning how to therapeutic strategies to be carried out at home. It is not enough for early childhood education providers develop workshops to satisfy a family engagement component for accreditation. There should be a feedback mechanism for families to share how they were treated during IEP/IFSP meetings, and whether they felt respected as equals on the IEP/IFSP team.

     d) Develop a pipeline for culturally and linguistically competent interpreters and providers. Temple Institute on Disabilities has a long-running program in which parents are trained and paid to provide interpretation services to other families. That is one important crucial to empowering families to be a part of the IEP/IFSP team. I believe another step is to make job descriptions for therapists available in multiple languages, create job opportunities in underserved communities by recruiting diverse individuals to train as early childhood education providers and early intervention therapists, so that families in those communities can select more culturally and linguistically appropriate providers.

     Thank you for your consideration.

446. I’m the mother of two young children on the autism spectrum. I am an active volunteer in my community here in Philadelphia. Recently, I began to partner with local agencies and Early Intervention providers to help them develop culturally and linguistically appropriate resources for undeserved communities. I wanted to share with you my experiences as a parent who is currently navigating this system.

     First, I want to commend U.S. Departments of Education and Health and Human Services for drafting this important policy and clarifying the obligations of early childhood education providers under IDEA and the Americans with Disabilities Act and the Rehabilitation Act (Sec. 504). As a mother who has searched for appropriate early childhood education providers, I have stopped counting the number of times that I or other parents called an early childhood education provider to inquire about their programs, and received the following responses:

     • “Is your child low functioning or high functioning?”
     • “Is your verbal or non-verbal?”
     • “Does your child get services? Will she or he come with an aide?”
     • “Does your child have behaviors? Is he or she aggressive?”

     For early childhood education providers, these may be initial “fact-finding” questions, but they are glaring indications that the early childhood education provider isn’t yet prepared to include a child requiring moderate or significant support in their current program. The CDC estimates that 1 in 68 children have been identified as being on the autism spectrum. It’s time for early childhood programs to be prepared to include the entire spectrum.

     Inevitably, during those initial calls to early childhood education providers, there is always one question that screens children with delays out, “Is your child potty-trained?” When a parent says no, the response is usually, “Oh, I’m sorry. Our preschool program doesn’t accept children still in diapers. Our facilities just aren’t equipped for that.” If the provider is sympathetic to the parent, he or she may even suggest, “However, you may enroll your four year-old in our (usually more expensive) toddler daycare program, which consists of two and three year-olds… but I know that’s not what you’re looking for. Sorry we don’t have anything for you. Good luck!”

     Aside from the fact that in a truly inclusive society, an early childhood education provider would offer to make a disability accommodation or add toilet training to the IEP, if appropriate, to support the child’s full inclusion in the preschool program, when a provider recommends placing a preschool-aged child on the spectrum in a program with two and three year-olds due to his or her toileting readiness, it suggests that the provider believes the child with disability is in need of daycare, but not a preschool education. Moreover, it would seem that the provider erroneously believes that a child’s abilities determine his or her “mental age.” Children with disabilities should be offered placements with their peers, not automatically assumed to be a better fit for children half their age.

     Sadly, the questions and comments above have been made to me by early childhood education providers with non-discrimination statements on their websites and colorful brochures featuring racially diverse children. These are providers who consider themselves to be good people, good boards, and good general counsel. Yet, sometimes I wonder whether they realize that ADA and IDEA are more than marketing gimmicks: these laws are intended to protect the rights of children like mine. I’m grateful to the Obama Administration for taking a bold step in clarifying early childhood education providers’ obligations to children with disabilities.

     When we are talking about what it takes to provide children with disabilities with high-quality early childhood education, I believe our federal government needs to examine the licensing ratios for day cares and early childhood education programs across the country. In Pennsylvania, the ratio for a preschool class is 20 children to two adults. The children range from ages 3-5, whose needs may range from socialization needs to kindergarten preparedness. When you add children with disabilities, two teachers are not enough to support the incredible range of needs in a classroom of 20 preschoolers. The sheer size and age range of typical preschools, particularly in urban areas like Philadelphia, make quality instruction extremely challenging even for the most bright and caring teachers. To make matters worse, my son’s teachers were usually out of the classroom for Head Start home visits, parent teacher meetings, staff meetings, conferences, and teacher planning. Year-round, substitutes were in the classroom morning and/or afternoon, which made it extremely difficult for there to be any consistent instruction. Even when there were wonderful, caring substitutes, the early childhood education program could not afford to schedule them regularly and therefore there was frequent staff turnover. When new adults were frequently shuffled into classrooms in order to meet Pennsylvania code for student to adult ratios, it was doubtful whether those adult read any students’ IEPs/IFSPs and/or have received proper training about inclusion, ADA, IDEA, English Language Learners, or their students’ disabilities. I invite policy makers to spend a day in a Head Start or urban preschool teacher’s shoes: attempt to teach a class of 20 preschoolers, with varying abilities and needs, in the limited amount of time you have in the classroom, while balancing other program obligations and a second job since Head Start doesn’t compensate well. Teachers, substitute teachers, and staff employed through Head Start (or similar programs) deserve better compensation to prevent staff turnover. Children with disabilities need consistency in their teachers. They need experienced teachers. They need teachers who are present to implement the IEP/IFSP. If you can increase the funding for teachers and staff employed through Head Start, you can help ensure that children with disabilities will have better quality instruction.

     Funding and program issues aside, across parenting message boards, there is a consistent theme that some early childhood education providers believe the inclusion of our children is a charitable act by the program, and not our children’s right under IDEA and ADA. In my experience, our IEP team tried very hard to communicate that philosophically, my son was to be educated in the least restrictive environment in his community with his peers. We believed the role of therapists was to share strategies with the school, for the school to learn how to teach to my child, for my child to be able to participate in the program as successfully as possible, and eventually to fade out supports when he was ready. Yet, it was evident to me through therapy session notes that in practice, when my son’s therapists arrived, he became their student, who happened to be receiving his services in a typical preschool classroom. When our IEP team made suggestions for modifications to teaching strategies or (God forbid) blanket rules prohibiting disability accommodations, the school was very set in their beliefs, which unfortunately predated the existence of IDEA and all the current research about autism. I think the culture of schools must change to respect the expertise of direct therapy providers and families.

     Ultimately, when our IEP team requested a more appropriate placement for the next academic year, citing issues with the curriculum, the early childhood education provider initially agreed to permit our IEP team to observe a classroom with a different curriculum. However, the visits never happened and the early childhood education provider informed us that we needed to make a decision immediately about whether we would remain in the current classroom. In other words, they were not going to give us a choice of classrooms. We chose to leave the program, as it was clear that they were no longer interested in supporting my son’s education. That is how I learned that even a highly lauded early childhood education program accredited by National Association for the Education of Young Children can completely fail to understand the basic principles behind IDEA and ADA. The only recourse that I had was to file civil rights complaints with the appropriate agencies.

     When parents of typically developing children tell me they have gone through four preschool or daycare providers before finding a good fit, I despair that families like mine must consider early childhood education providers well outside of our communities and outside of our budgets. The search for an appropriate, inclusive provider is a drain on time, money, and resources. Computer literate parents may resort to contacting parent listservs, asking for other families’ recommendations. However, as any parent reading this comment knows, a welcoming program can turn into a bad program with the departure of a specific teacher, a program administrator, or the director. Programs can and do change year to year. Therefore, word-of-mouth isn’t even reliable. While early intervention providers are rightfully expected to empower families when they identify problems with programs, the reality is therapy providers and individual contractors must remain on civil terms with agencies and early childhood education programs. Fear of retribution or lack of knowledge about how to report discrimination are real barriers.

     Therefore, while this drafted policy brilliantly outlines early childhood education programs’ obligations, I believe the family engagement piece needs to be more robust.

     a) Hold early childhood education programs directly accountable. Thomas Jefferson University has a program called Philadelphia Inclusion Network (PIN), which has done trainings for early childhood education providers for years. What if the federal government provided funds to states toward the creation an online directory of early childhood education providers who have undergone training on inclusion? The online directory should have a rating mechanism so families can leave reviews about their child’s inclusion in the early childhood education program. Providers that post non-discrimination statements and go through great lengths to receive accreditation, only to knowingly violate ADA and IDEA, would finally be held accountable.

     b) Require language access plans in family engagement efforts. The U. S. Department of Health and Human Services, with its Office of Minority Health, developed national standards for Culturally and Linguistically Appropriate Services (CLAS) to assure that all individuals regardless of their background or culture have access to quality health care. When it comes to serving children with disabilities, I believe the same principles need to apply to early childhood education. When I talk to immigrant parents, they cannot read therapy notes written in English, nor are they aware that they have a right to an interpreter for IEP meetings. The reality is that these families have a right to interpreters and translated documents. I am working with Pennsylvania Office of Child Development and Early Learning and Pennsylvania Training and Technical Assistance Network to develop family’s rights materials in plain language, and to bring that information in various formats to the grassroots. This should be happening across the country.

     c) Assess the efficacy of current family engagement efforts and develop metrics for inclusion of the family in the education of their child. It is clear to me that some early childhood education programs take a paternalistic attitude toward parents of children with disabilities, assuming that parents or grandparents are too ignorant to be experts on their children’s educational needs, or that immigrant parents or grandparents in particular will not be interested in learning how to therapeutic strategies to be carried out at home. It is not enough for early childhood education providers develop workshops to satisfy a family engagement component for accreditation. There should be a feedback mechanism for families to share how they were treated during IEP/IFSP meetings, and whether they felt respected as equals on the IEP/IFSP team.

     d) Develop a pipeline for culturally and linguistically competent interpreters and providers. Temple Institute on Disabilities has a long-running program in which parents are trained and paid to provide interpretation services to other families. That is one important crucial to empowering families to be a part of the IEP/IFSP team. I believe another step is to make job descriptions for therapists available in multiple languages, create job opportunities in underserved communities by recruiting diverse individuals to train as early childhood education providers and early intervention therapists, so that families in those communities can select more culturally and linguistically appropriate providers.

     Thank you for your consideration.

447. This bill can not be a one size fits all. My son is on the autism spectrum and was in an ECE program. He definitely benefited from being with his typically developing peers. However, with Deaf and Hard of Hearing students, the list restrictive environment is most often with other deaf or hard of hearing peers, with whom they can communicate.

448. Although a critical concept, I’m somewhat concerned a large emphasis of this document is being placed on cost and using a single study with a relatively small n. The requirement of districts funding portions of private pay preschools in most States has a significant cost implication as well as a litigious one. We should continue to expand collaboration between head start and other public programs, but until the private community program issues can be addressed in the law this will remain too costly for most districts to implement for students with more significant and behavioral needs.

449. I have an 18 month old daughter who has Down syndrome and I hope that she will be able to attend an all inclusive preschool and have the same benefits as typical children. I believe that children with disabilities should be included in early childhood settings in natural proportion to their presence in the general population. I also believe that early education provides significant benefits to all young children, both with and without disabilities.

450. To include special needs children with typical children in proportion to their number in the general population would be a true gift to these misunderstood children. From the day my grandson with Down syndrome was placed in a summer camp program with this type of inclusion, he went from being a very slow learner with few skills, to being a happy little boy who is rapidly learning to speak, dance and participate in group activities. His progress has been nothing short of miraculous from the very first day. He came alive. I have no doubt that all children benefit from this mix. Typical children learn to appreciate and value the unconditional love and goodness that come from these special kids.

451. My great-nephew is seven months old and has been diagnosed with Down Syndrome. I appreciate every effort to afford him the opportunity to be included in early intervention and all educational programs. Unfortunately, his family resides in a rural county in Ohio that does not offer speech therapy, occupational, or physical therapy until he is school aged. This is so disheartening.

452. I agree 100% and support this initiative to ensure young children with disabilities are able to participate in early intervention and other therapeutic or educational programs. My daughter is 18 and has Down Syndrome. The Early Intervention program she participated in benefited her in all areas of learning and development. I truly hope our government will continue to provide funding for these much needed programs. We owe it to our children to provide essential educational opportunities at all ages.

453. Thank you for pushing this forward. We struggle every day for inclusion in our elementary/middle school and I know high school is going to be even more of a struggle– mostly against attitudes. I understand why the focus in this draft is on starting in preschool, but we must have inclusion for all ages now!

454. As a parent of a child with Down syndrome, I fully support the U.S. Departments of Education and Health and Human Services policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. My son attended private preschool for half the day and spent half the day at the preschool of our LEA, who did not offer inclusive placements for preschoolers with disabilities. Although this was a more expensive route, the benefits were clear in the social and speech gains he made. Having my son educated with his non disabled peers has been immensely beneficial: he is now in first grade and thriving in a general education setting. Thank you for sending a signal of strong support for inclusion at an early age. I hope this policy will continue to promote a culture of inclusion for people with disabilities in elementary and secondary education and beyond.

455. I want to shout it from the rooftops, I am in such agreement with this policy!!! As the parent of a four-year-old son with Down syndrome who attends a “typical” pre-k in a public k-8 school, we have seen exponential growth in speech development and physical coordination since he started school. Our son is easily the most popular student on campus and has built genuine friendships with his school,ages. It’s a true testament to the power of inclusion and we hope he will see continued success as he grows. His occupational, speech and physical therapies are pushed into the classroom on a weekly basis. He fully participates in classroom activities and it’s heartwarming to see how much his classmates love him. Kids in other classes jockey for a position near him in the cafeteria at lunchtime and he walks a gauntlet of high-fives and hugs every morning.

456. Please consider that a heterogeneous grouping of age-related peers is not the best educational environment for all children; it never has been. This is the very reason for Individualized programs. Deaf children in particular benefit most from a barrier-free communication environment, which seldom exists in so-called “mainstream” settings. “Special” Education was established for a reason. Please do not return us to the days of yesteryear. We have come so far; this legislation would drag us backward..

457. A critical component of my son’s early intervention ABA program was three mornings a week with neurotypical peers in a private university preschool with the support of one of his trained ABA home therapists. He learned compassion, empathy, and was directed to generalize his newly acquired skills and “embed” them into his regular repertoire. Most important was the opportunity for mimicking healthy, age-appropriate behaviors and interactions, especially speech. It breaks my heart to know that 23 years later this is still not happening automatically in this country. All children with disabilities should be immersed in preschool programs with appropriate supports under the sme fedrl and state las that govern their late full inclusion. To know that my grandchildren could face the same obstacles as my children is sad indeed…..

458. Our son who has down syndrome experienced the benefits of inclusive education in a private day care from 4 months to 5 years and then a parochial school from K through 4th grade. As a result, he has developed good reading and math skills, has had the opportunity to develop good friendships, participate in mainstream sports, been invited to birthday parties, and otherwise develop many age-appropriate skills. His main barrier to continuing in an inclusive setting is a lack of understanding and support by the parochial school’s administration and faculty.

459. As an Early Childhood Special Education teacher in a district that, as of this year, only offers inclusion options, it is heartening to see that this long-overdue spark for change is finally happening and is receiving attention from the federal level.

     In reviewing the proposal, I would add that states, LEA’s, and districts need to establish a ROBUST continuum of inclusion options. I fear that even with the best of intentions, “inclusion” will too easily become “one size fits all” when in comes to the classroom environments where children are placed. Inclusion – especially in early childhood – does not, and should not mean that a student with an IEP is placed in a classroom of 24, or 20, or even 18 three-to-five-year-old children. Many children (both typically developing and those with special needs) do better in smaller settings. The environment is more comfortable to all the senses, the social-emotional connections (which the proposal points out is so critical) have a much greater chance of fostering, and the classroom staff can really get to know the children; increasing the possibility of individualizing and differentiating instruction. For further information, see http://nieer.org/resources/policybriefs/9.pdf and https://www.whitehutchinson.com/children/articles/35footmyth.shtml

     Directly linked to the points above is the issue of early childhood training requirements for teachers. Some states (and some districts) have already set the requirement for a Bachelor’s, or have started making the move toward more rigorous training, but many more are sorely lagging behind. I find it indefensible that parents (in general) are expected to put their children’s safety and well-being into the hands of a teacher who has had who has taken, in the case of my state, California, 4 college-level classes (12 units) and maybe a semester of practicum. Many teachers have this level of training and are wonderful and professional – they seek further professional development, or they join or create their own professional learning communities…but there need to be established and regimented courses of training for early childhood teachers if they are expected to implement the full scope and range of procedures, principles, and strategies that are necessary for supporting all students.

     If the above were implemented, then, and only then, can the INDIVIDUAL in IFSP or IEP be honored and upheld.

460. I understand the overarching plea for inclusion of students with disabilities, but I need to echo the sentiments expressed by the Deaf Educators included in this blog.

     Please do not group Deaf and Hard of Hearing students in together with all other disabilities represented by this proposal of policy. In Deaf Education, we have come a long ways through evidence-based research and frustration to see the outcome of the argument of inclusion and misfitted placements that do not benefit a Deaf child.

     LRE means a school environment where a Deaf child can effectively access language, and this does not necessarily occur in the home school district. I work at the state school for the Deaf, where we see time and time again, students who arrive at our school late in their education, who have suffered the affects of severe language deprivation due to the lack of exposure to signing models, strong familial support, and professional expertise in Deaf education. At the Deaf school we try and play “catch up” to provide functional literacy skills to these students before the age of 21. It’s disheartening to say the least.

     Inclusion for a Deaf/HH student in a mainstream setting would beg us to ask: are they truly included? They may be provided access through a third party adult sign language interpreter, if they can use ASL to communicate. How is this inclusion with their peers?

     We have Deaf schools in most states so that direct instruction can take place, so that students can access information freely and without barrier or interpretation, so that students can learn directly from and beside their peers in a natural manner, and so that they may learn leadership skills, especially from other Deaf adults. Deaf children become Deaf adults who can graduate with standardized diplomas, move onto achieve degrees in higher education, and eventually teach and lead the next few generations of Deaf students in education. That is the beauty of successful Deaf education.

     We have world renown universities that research these issues thoroughly, and they continue to support Deaf schools as the most effective holistic approach to Deaf Education due to the language accessibility issue.

     Deaf children will navigate the hearing world their whole lives. We need to support Deaf schools in partnerships with regional programs to give these particular children that conduit for learning survival skills, learning English visually, and finding success as bilingual citizens through ASL/English.

     Please don’t jeopardize the tried and true method of educating Deaf students with their own critical mass of Deaf peers at Deaf schools by promoting “inclusion for all.”

     One size definitely does not fit all.

461. As a parent of a 3-year-old daughter with Down syndrome, I fully support this policy. Inclusion is successful, evidence-based, and benefits both kids with disabilities and their typically-developing peers as well. There are so many benefits to this both short-term and long so I fully support this legislation.

462. I want to thank the U.S. Departments of Education and Health and Human Services for the policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs.

     I energetically support the desire for full inclusion in natural proportions. Studies show, time and again, that inclusion is the right move for all children and it produces the best academic and social outcomes.

     The recommendations for state and local education agencies will help change the system, so it is not as difficult for parents to find inclusive early childhood programs or as difficult for our children to be successful.

     The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond.

     For my child, she was put in a “special” preschool where the only inclusion was from typical kids of families with children in the program. TO keep these children, and their families separate, the District offered heavily subsidized preschool for typical children, but hid the school from public view. It was never listed on any website nor mentioned in any District literature. Because of the heavy subsidy, our families jumped to put our typical kids in the program – and because we want our sibling-children to gain empathy. This is heartbreaking segregation from the very get-go. And it is still happening in 2015 – in Districts who pride themselves in performance and achievement for their typical students. We can do better than to castigate families and offer sub-par educations to children.

463. As the retired President of a school for the deaf which pioneered the use of inclusive classrooms for deaf students I have some concerns. My school operated two campuses one centered based and one embedded in a public school. Our vision was the most enabling environment for each of our students based upon comprehensive assessments. There are clear benefits from an inclusion setting but similar benefits exist in specialized environments We must maintain a continuum of opportunities for young children and the placement decisions should be based upon findings and reviewed regularly to determine if changes are needed. It is standard of practice which will provide every advantage for children.

464. I would like to say having a legal definition of inclusion will be a great help to parents, advocates of inclusion, schools and teachers. With a clear definition in place by US Dept. of Ed IEP teams can all have the same vision of inclusion in mind when it is discussed.
     I would like to say I fully support the definition as it is in the Draft Policy Statement.

465. There is a strong research base to support the education of children with disabilities alongside their non-disabled peers. The challenge is not whether to provide inclusive education, but how to implement inclusive education in ways that are both feasible and effective in ensuring schooling success for all children, especially those with special needs. Segregated education is an abysmal failure.

466. Inclusion is much more than just being in proximity with peers. For a child whose needs are not being met or who isn’t purposely and actively engaged with other children and with the activities, we are doing them a disservice that will have long term consequences. Mandating one approach for all children flies in the face of IDEA. Each child deserves to have the best possible opportunity to meet their individual identified needs.

467. I am thrilled to see that you have incorporated HIGH EXPECTATIONS for all children, including children with disabilities (CWDs), in your inclusion statement. Believing that most children CAN be successful in inclusive environments is the first step.

     I concur with the statement “Special Educators and Related Service Personnel should deliver services to children with disabilities in early childhood setting and embedded in everyday routines and/or co-teach and coach general early childhood teachers, as opposed to working with children in separate settings or pulling children out of their settings for specialized instruction.” We know that pulling children out of natural environments does not equate to generalization of skills.

     In Michigan, the EC endorsement on a teaching certificate now means the teacher is certified in general and special education. This move is supported by the statement “Teachers and Providers should have the skills necessary to meet the learning needs of children with diverse needs.” We are seeing teachers who are better prepared to teach CWDs.

     Thank you for highlighting the fact that time is limited with our current level of resources.

     • So well stated! Thank you for posting. We LOVED our inclusive education in MI, k-8th grade!

468. Children with disabilities are entitled to the Least restrictive/Most appropriate/Natural environment. I fear this new language will allow states and school districts the opportunity to find ways to further “Go Cheap” with addressing the needs of children and the most appropriate environments may not be considered. Early Intervention and Preschool Education in my state have been so watered down that children are now almost unable to access appropriate services at the level of their need without legal representation holding government and school districts accountable to the law.

     There should not be a policy on inclusion, policies should follow the law and it should only say LRE/Natural Environments and placements that are approved by the IEP and IFSP Team, anything else will prevent children and students from being served appropriately. The law ensures that ALL students are served based on their individual needs, it works if implemented correctly. This policy is trying to push one placement over another, this is not your responsibility, this responsibility belongs to professionals and parents. You must appropriately implement the current law, not set policies that contradict current law.

     it is critical that services be provided in the appropriate environment early not simply having ALL children in a one size fits all system.

     • As a special education teacher, mom and current BCBA student, I could not agree with you more. Some children will benefit from an integrated preschool program providing they have certain developmental skills in place (verbal operants, joint attention, etc.). However, a child who is not able to attend or follow simple directions and have limited to no understanding in regard to safety skills or understanding what is happening in their environment, should not be required to attend a program that will not meet their individual needs.

     • I can’t agree more with Joseph C. On LRE. This especially applies to Deaf and Hard of Hearing (DHH) individuals who are learning sign language while progressing in their academic life. Most DHH children are born to hearing parents who, in the majority, receive limited educational information and who do not learn to sign thus delaying their child’s language/social-emotional development. Asking these children to be integrated in the gen Ed classroom without the right tools and strategies, not to mention a fully, acquired language, is setting them up for failure…this is unacceptable and will potentially hurt them in the long run.

469. As a parent of a 9 year old son with Down Syndrome, I want to express my full support for the Policy on Including Young Children with Disabilities in Early Childhood Programs. When my son was a preschooler, our school district did not provide any inclusive placements for preschoolers with disabilities. They only offered special day class preschool which was made of all students with disabilities. I had to go and find on my own a private preschool in town that would accept my son and then had to help pay for an aide to support him there. I created the best option I could out of what was offered, so I sent him to the district’s special day class preschool 3 days a week so he could continue to get his specialized instruction and therapies and then put him in the private typical preschool two days per week. I wish the district had offered an inclusive placement option or had been willing to support Liam at the private preschool, that would have been better. Thank you for the strong support for inclusion that you are sending with this policy. My son is included in general ed now and has been since kindergarten but it has taken much advocating on my part and my school district’s special ed administration still doesn’t believe in inclusion or understand its benefits.

470. Yes! Include all students together! No doubt!

471. As an anthropologist specializing in early childhood and parent to two young children, one typically developing and one with disabilities, I want to express my unconditional support for the full inclusion of young children with disabilities in ECE/ECD programs. A large body of research has proven that inclusion has educational benefit for all children, because it starts with best practices from which every kid can benefit.

     Children with disabilities often find their human rights, and inclusion in society, jeopardized. Their contributions are overlooked, their abilities go unaccounted for, and their needs are not prioritized. These barriers, however, are more frequently derived from their environment. Often they are not the direct result of a child’s particular disability.

     Disabled children’s social and educational experiences vary widely from state to state and federal policy is critical to new opportunities for disabled people in the arenas of education, independence, advocacy, and everyday life.

     Seeing how disabled children forge educational opportunities and create futures as they navigate complex social, political, and economic structures that privilege able bodies is a critical lesson in resilience for all children. At the same time, young disabled people represent a crucial voice of difference in our classrooms. They offer us the opportunity to teach about stigma, discrimination, and value – and how these are intertwined.

     Inclusion involves all children, and at early ages it often comes quite naturally to them. It gives children the experience of growing up in an environment where diversity is normal, not an aberration. One underlying cause of the social marginalization and economic exclusion of the disabled is that the education system fails to consistently provide for and accommodate the diversity of human experiences at an early age. Opportunities for true inclusion are exceedingly rare, and hard won, in the United States.

     The inclusion of children with disabilities is an investment in our moral and economic future. It is not a gesture of charity or compliance. Inclusion is integral to citizenship, civil rights, and social justice.

     • I have personally witnessed the benefits of having toddlers with deveolpmental delays included with typically developing toddlers. I opened an inclusive learning center a year and ahalf ago. I have toddlers with Down Syndrome and typically developing toddlers. I just recently conducted the BDI-2 evaluation for one of the children with Down Syndrome. She did noot qaulify for services according to the evaluation. She will continue to receive her service because of her diagnosis. I know for a fact because of her opportunity to be in a learning environment with typically devloping kids, she excelled to the degree she has reached. She looks at them, observed them and is now modaling after them. She uses two word utterences, has spontaneous words, and is proficent with using sign language. My purpose and goal when I opened the learning center was to give children with developmental delays the same opportunities as typical kids to a good educational foundation. By the time the exit the learning center at three years old, they would have been exposed to an educational setting which consist of structured activities as well as child directed activities. I’ve had a couple of students who did not qualify for Early Steps because they were only delayed in one domain. After leaving the learning center they were using sign language, an increase in vocabulary and 2-3 words in Spanish. My learning center is modaled after the Early Intervention Program of Ochsner hospital inn which I was the Special Instructor for ten years. Also, LSUHC had the same program. Sucess stories I can tell you are a mile long from each of those programs. I feel staring the kids at an early age with the right intervention will definetly help them when they enter pre-school. If you would like more info about my learning center feel free to email me or call me. 504-394-6245 Thanks for caring an supporting the children with deveolpmental delays.

472. Inclusion all the way!!
     Yes include all children in high quality programs and schools.

473. Although inclusion sounds like the ideal- for many children that is not a reality. Especially at the pre-school level, many children require significant individualized approaches which can not always be implemented within a typical classroom setting. There should not be a policy on inclusion; policies should follow the law and it should only say LRE/Natural Environments and placements that are approved by the IEP and IFSP Team, anything else will prevent children and students from being served appropriately. The law ensures that ALL students are served based on their individual needs, it works if implemented correctly.

474. As an Occupational Therapist who currently works with preschool children both in inclusion and in specialized classes, I strongly believe that children should be given the opportunity to socialize, learn, and grow in an integrated setting. It is however essential that each child be looked upon as an individual and they receive the proper help that is needed for their success such as a 1:1 paraprofessional, push-in related services, specialized learning materials such as large print books, added time, sensory plans and routines to help them organize their sensory systems, and all staff are well trained how to successfully work with that child. If the child cannot handle being in an integrated classroom with a large number of peers, they must have the option to learn in a smaller setting such as a specialized 6 student classroom, working in a more structured environment with highly trained staff. An integrated child who is improperly placed and not receiving the individualized help that he needs will often become overwhelmed in an environment that is over stimulating. How then would that problem be solved? If there is no successful solution and plan, the teacher will spend most of his or her time addressing disruptive behaviors as opposed to teaching the curriculum. All children will then suffer. I have seen this way too often. This is why it is essential that children placed in an inclusion setting receive push-in related services, 1:1 teacher assist, a collaborative team approach with parents and medical professionals working with that child, and any other supports needed.

     I also highly recommend that the U.S. Department of Education create a standard which screens children for visual skill delays, especially those placed in inclusion settings. Visual skill delays are a widespread problem too often overlooked, particularly with children who are labeled dyslexic, juvenile delinquent, and learning disabled. Vision problems often lead the child to develop avoidance behaviors which mimic these common diagnoses and the child loses self-esteem as a result of not being able to keep up with academic standards. Current screenings for eye health and 20/20 vision and sensory integration strategies alone are not enough. The American Foundation for Vision Awareness has found that vision disorders are the fourth most common disability in the United States and the most prevalent handicapping condition in childhood, affecting between 8-12 million children. I see this all the time with children that I treat in the school system. There is almost always an underlying vision problem such as eye movement control, eye teaming, peripheral vision, visual memory, eye hand coordination, visual closure, figure-ground, in addition to delays in the vestibular and auditory system which go undiagnosed. Visual processing delays, once discovered, can be addressed and rehabilitated by trained professionals such as a Behavioral/Developmental Optometrist or a trained Occupational Therapist. One does not need to be a doctor to learn how to do these visual screenings and assessments. There are trainings available for persons who are interested.

475. Hello I Agree With This Law Or Bill We Should Allow Young Children With Disabilities To Join Early High-Quality Childcare And Childhood Programs Myself Also Have Disability So I Would Like This Bill Or Law To Be Pass Everywere in These 50 States of USA.

476. As an anthropologist specializing in early childhood and parent to two young children, one typically developing and one with disabilities, I want to express my unconditional support for the full inclusion of young children with disabilities in ECE/ECD programs. A large body of research has proven that inclusion has educational benefit for all children.

     Children with disabilities often find their human rights, and inclusion in society, jeopardized. Their abilities are overlooked, their capacities are unaccounted for, and their needs are not prioritized. These barriers, however, are more frequently derived from their environment rather than as result of a particular impairment.

     Disabled children’s social, moral, and educational experiences vary widely from state to state and federal policy is critical to new opportunities for disabled people in the arenas of education, independence, politics, and everyday life.

     Seeing how disabled children forge educational opportunities and create futures as they navigate complex social, political, and economic structures that privilege able bodies is a critical lesson in resilience for all children. At the same time, young disabled people represent a crucial voice of difference and diversity in our classrooms. They offer us the opportunity to teach about stigma, discrimination, and value – and how these are intertwined.

     Inclusion involves all children. It gives children the experience of growing up in an environment where diversity is normal, not an aberration. One root of marginalization and exclusion is when the education system fails to provide for and accommodate the diversity of human experience.

     The inclusion of children with disabilities is an investment in our moral and economic future. It is not a gesture of charity but an integral element of citizenship, human rights.

477. Having been in the field of deaf education for 41 years, I have seen the impact on the lives and educational attainment of children who have been in “inclusive” settings without the specific services and supports necessary for a deaf/hard of hearing child to learn and thrive. The concepts of Least Restrictive Environment (LRE) and inclusion have been broadly misinterpreted where D/HH children are concerned. LRE has become equated with neighborhood school. Inclusion has been promoted as the optimal goal for all children, with minimal attention given to the impact on D/HH students whose needs are not being met in those settings.

     I work at a school for the deaf. We maintain data on new students that enroll in our school each year. The average reading, language and math levels for students in 9th – 12th grade when they enter our program is between kindergarten and first grade, sometimes second grade. These are students who have been “included” year after year without regard to the educational progress they were making or the social/emotional impacts to their development. Inclusion is not mandated by IDEA. It is not found in the law. Please do not further institutionalize a concept that has already had such a damaging effect on so many children and adults.

     A setting can only be considered the LRE for a child/student if the necessary language and communication environment exists that allows students to have full access to information at all times, in the same way hearing children have access. Providing an interpreter does not ensure full access for many reasons. There may not be a match between student language choice and level vs. interpreter language choice and level. The dependency on an adult in order to communicate with teachers, peers, and related services staff does not promote independent communication and likely hinders social/emotional development. We know language learning is a social activity and that students learn best from their peers. D/HH students’ educational environments need to reflect this.

     Schools for the deaf are not for all D/HH children; but neither are neighborhood schools appropriate for all D/HH children. IDEA provides for a continuum of placement options. Please do not issue policy guidance that undermines the law and undermines the critical work schools for the deaf are doing. In so many cases, schools for the deaf receive students who have been badly damaged and delayed, and provide them with a chance for a future. They offer the specific services and supports D/HH children need to learn, including seeing successful deaf adults who serve as role models for students and help them create a dream for their own lives. Public schools should be taking advantage of the incredible resource the school(s) for the deaf in their state are, and working together to provide the best education for D/HH possible. We expect this for hearing students; D/HH students deserve no less.

     This policy statement is not specific to D/HH children, but it will greatly impact D/HH children, in the same way many of the provisions of IDEA have been good for many disability areas, but have had negative implications and impacts on D/HH students. One size does not fit all. Please do not issue further policy guidance that will hurt D/HH children.

478. Our district has been a firm believer of providing an inclusive environment for early childhood students. What hasn’t alligned is the practice of reimbursement for classrooms that seek to be more inclusive, such as having a 50-50 ratio of typically developing students to students identified with needs. There is a descrepancy between what the LRE practice is and the auditing practice for how our classrooms can be structured.

479. As the parent of an adult son who experiences significant intellectual disabilities, I am grateful for this draft policy statement on the inclusion of young children with disabilities in high-quality inclusive early childhood programs. Disability is normal. It occurs in low frequency, yet is is a normal part of living in this wide, rich world.

     We now have accumulated abundant anecdotal and evidence based information about the benefits of inclusive practices and resources for all children beginning in early childhood years. The time has come to leave separate educational models behind and welcome all children into rich early childhood educational settings. The recommendations for state and local education agencies will help change tired systemic practices that make it more difficult for students with disabilities to experience success on their educational and life journeys.

     Two suggestions are particularly important to me. First, I support the recommendation to include children with disabilities in proportion to their presence in the general population (natural proportions). Secondly, I support the recommendations in this policy statement about creating foundations on which to build policies to support inclusion in elementary and secondary education and beyond.

     Having worked until I was bone weary to effect inclusive options for my son, it is my hope that this statement will ease access for families of young children so that their educational career may begin on an inclusive path, likely to promote life long learning and community contribution, in lieu of their having to travel along a segregated path, where immersion in disability culture and practices inevitably stymies efforts to create bright, fulfilling futures.

480. I am a parent of a child with Down Syndrome. We were fortunate that my daughter was in an excellent Early Intervention program and started receiving services at three weeks. Some years ago, it would have been likely that my daughter would have been either institutionalized or would not have received any services until reaching school age. It is incredible how much progress my daughter had made by the time she started kindergarten. She is in first grade now and has to be bused out of district because our school district does not have placement for her. Our district’s Special Education programs are all autism based and not suitable for Down Syndrome.
     We hope that by next year she will be able to be in an inclusive class in our district. She is growing up in our community where she doesn’t know any children because she doesn’t attend school with them. Any community activities in her present school are many miles away from our neighborhood. We are very grateful that she did find a school that welcomed her and provided services for her, but she is growing up separated from the children in her own community that she will live among for the rest of her life. I believe that the Draft Policy Statement on Inclusion would help put some pressure on School Districts to address the need for Inclusive school programs and classes for children with disabilities, instead of simply shipping them out to other , sometimes distant districts, or just throw them together into a class regardless of the differences in their disabilities, just to keep them separate. I believe that having disabled children among typical children benefit both, especially since they will be part of the same community, instead of segregated from each other.

481. It is very important that the needs of Deaf and Hard of Hearing children who use American Sign Language (ASL) be considered. Inclusion in the closest “home school” is often the most restrictive environment for young Deaf and HoH children. For these students, a language environment where adults and peers are using ASL as the language of instruction and social interaction would be the least restrictive environment. If the language needs of the student are not met, then the FAPE requirement is not met.

482. As an Early Childhood Project Manager, I am very involved with the Latino population of parents. It is very important to consider the experiences or perceptions that immigrant families have with these topics from their country of origin as a baseline when raising awareness. Then, and only then, family involvement efforts will be effective. Also, we need to share this information with teaching staff and family service workers. When they understand why families react to disability issues, they can be more empathetic and build better communication and engagement strategies. We need to help immigrant parents navigate this new system to help their young children.

483. My nine-year-old granddaughter has Down Syndrome, and is quite high-functioning. She is in 3rd grade in a Catholic school. She is doing quite well, reads well and is an avid reader. So far, very few accommodations have been necessary, and the only subject in which she is not ‘included’ is math–she has a retired teacher who volunteers at the school and who works with her on her math. In my opinion, a great deal of her successes have to do with her family, many of whom are or were teachers, who raise the bar for her to the same level as her siblings. She plays sports (softball, soccer), in an incredibly good swimmer and paddleboarder; she’s in scouts, sings in the choir, is learning to play the recorder. She has an incredibly well-developed sense of humor and ‘get’ irony. She’s one of the most popular students in her school, due in part to her positive and cheerful attitude. She should/could be the poster child for the positive effects of early intervention.

     In my opinion, this act is long overdue; every school district in this wonderful country of ours, and particularly in our great state (Florida). It has been proven that EI does work!

     Thank you for letting me express my feelings on this most important issue that relates to education of our most valuable resource, our precious children.

484. I respectfully disagree with these departments’ amendments to the current law. As a special needs transition coordinator, I believe that the programs that we have established which prioritize functional life skills and community experience will be negatively impacted. We currently are able to work with autistic students to teach them social/life/job skills that set them up for success. Each child is able to reach their individual potential because we don’t use the cookie-cutter goals that will force every child to fit the mold, or fail. We are able to work at whatever pace the students are capable of working to get them to reach their goals and have had great success. We take great pride in our ability to push the expectations and help each child reach their individual potential.

     By adding the verbiage of “inclusion,” many of our students will be prevented from receiving the individualized care that is required to serve them best. The current phrasing of the law states that students should be in the Least Restrictive Environment. This means that students could be “included” if that is the most appropriate and least restrictive placement. For the examples listed in the comments sections of parents disappointed in the current law, I think that there is misunderstanding of the fact that these students have the option of being included. IF THE LANGUAGE IS CHANGED IN THESE LAWS, the students who are thriving in our program will not be given this choice anymore and each child will be forced into a placement that may not particularly suit their needs. This is the responsibility of parents to decide, not lawmakers.

     I urge you to reconsider this language that is being proposed because it will be detrimental to the students with which I work. Even in specialty schools specifically designed for the students that are low functioning and unable to thrive in an “inclusive” classroom, we integrate them into the community by taking shopping outings and setting up community based learning experiences at places such as grocery stores, restaurants, gyms, hotels, nursing homes and various retail stores. This would not be possible if the amendments are made. We do not allow any student to be forced into cookie cutter goals that are below their abilities and potential.

     Please DO NOT CHANGE THE CURRENT LAW which allows for this type of inclusion if parents and school officials deem it appropriate, but does not FORCE IT ON EVERY STUDENTS FOR WHICH IT IS NOT APPROPRIATE. The current law is sufficient and simply needs to be implemented correctly.

485. As a long time special education teacher and administrator, I feel that inclusion is appropriate for some but not for all. We are here to meet the individual needs of our students, which does not always mean that an inclusive environment is the most appropriate. If we go back to this, we will have a lot of students sitting in the back of the classrooms, not getting their needs met, all for the sake of inclusion? The students are entitled to a free and appropriate public education. Inclusion is NOT appropriate for all students.

486. As a parent of a child with special needs that benefited from early inclusiong, I support this policy and hope it will be officially released as soon as possible. The clear message in the policy statement about the benefits of inclusion and the resources provided in the appendices will help me as I advocate for my child. The recommendations for state and local education agencies will help change the system, so it is not as difficult for parents to find inclusive early childhood programs or as difficult for our children to be successful. An especially important recommendation is the inclusion of children with disabilities in proportion to their presence in the general population (natural proportions). The recommendations in this policy statement create a foundation on which to build policies to support inclusion in elementary and secondary education and beyond.

     My daughter is now 16 and has been largely in an inclusive setting since pre-K. Inclusion at an early age helped her both academically and socially. She started developing study habits and modeling behavior that would have been difficult in an isolated setting. She also made good friends that she has shared who entire school experience to date. These friends truly see her as a friend and not a ‘special needs kid’ and this would not have been possible without inclusion. This exposure is not just helping my daughter but helping all of her peers to see the benefit of not just inclusive schools but of an inclusive society.

487. As a professional in the field of Deaf Education, I have some grave concerns about the one size fits all nature of this document:

     • “Inclusion” is not mandated by IDEA. The word “inclusion” does not appear in IDEA at all. IDEA is based on the concept that decisions about children and families must be made on an individual basis. IDEA requires: the child to be appropriate evaluated by qualified evaluators; the IEP team to develop goals for the child, based on those needs; a description of services that are necessary to help the child achieve those goals; and after those processes are complete, a placement decision made based on those steps. The team that decides placement must include the parents. This document focuses on “inclusion” without addressing the steps necessary to determine appropriate placement.

     • IDEA requires public agencies to provide a continuum of alternative placements, which includes special classes and special schools. Any placement on the continuum can be considered the Least Restrictive Environment for a particular child, given the child’s individual needs. This document incorrectly assumes that LRE is always the general education environment.

     • The U.S. Department of Education has stated on many occasions “any setting that does not meet the communication and related needs of a child who is deaf does not allow for the provision of a free appropriate public education (FAPE) and cannot be considered the LRE for that child. Just as the IDEA requires placement in the regular education setting when it is appropriate for the unique needs of a child who is deaf, it also requires placement outside of the regular educational setting when the child’s needs cannot be met in that setting.” This document disregards factors that should be considered in determining placement for a deaf or hard of hearing child.

     • Studies purporting to show the benefits of “inclusion” generally do not include deaf and hard of hearing children. Studies that do look at deaf and hard of hearing children indicate that they children experience great difficulties with communication with peers in general education settings.

     • Specialized schools and programs for deaf and hard of hearing children include qualified professionals who are trained and experienced in working with deaf and hard of hearing children and their families. These programs are intentionally designed to ensure that children have full language and communication access in the school with professionals and peers. They offer deaf and hard of hearing adult mentors and role models as well as a wide range of services such as speech-language-pathology, audiology, cochlear implant support, sign language support, parent counseling and training, physical therapy, nursing, and others. Programs and agencies should optimize use of these schools and programs.

     • This policy statement is not needed. The Americans with Disabilities Act and Section 504 of the Rehabilitation Act already require early childhood programs to be accessible to children with disabilities. This draft guidance misinterprets the law and creates confusion.

488. I am the prek director for a school district that has been practicing inclusion for years. I am extremely happy that inclusion could become the “norm” for young children in our educational system.

489. As a retired professor of early childhood/early childhood special education, mother of a son with developmental disabilities, and special education consultant, I support inclusion as early as possible. Key issues in this document are training of all partners in this venture, including family members, licensed/certified professionals, childcare staff, and community members. Family members may be the most important, as they carry the advocacy of inclusion into school-based programs, and adult programs. Specialized training for licensed professionals (including needs connected to challenging behaviors) that provide services within all programs where we find young children is needed; not just within public school systems. I hear often “we do not have the funding.” Interpreted in a different way, it can be translated to “we do not know what we to do to fully include children.”

490. The draft policy sets the standard for universal access for all children. In MI. we have a strong MI Interagency Coordinating Council. The Head Start Act does have specific programs that support high quality early learning opportunities for children with disabilities, however, it seems attitudes and beliefs are interfering with the opportunity for access for children with disabilities. This policy could perhaps improve the opportunity for children with disabilities to attend Head Start. Head Start teachers would be highly qualified, would attend PD to gain a better understanding of the strategies that could be used to improve outcomes for children.
     In MI we have a coordinated early childhood PD system that provides up to date, research based P D for all Early Childhood Providers.
     I strongly support the State Recommendations as well as the Early Childhood System Requirements to improve the outcomes for all young children.

491. I support the Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education. However, I agree with other posters that the current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”. I also agree that it is unfair for parents to pay for inclusive early childhood programs themselves and then allow the districts to get credit for those placements.
     Finally, I would recommend that you emphasize in your policy statement that all children in inclusive early education programs have access to related services providers-especially Occupational Therapy Practitioners. Occupational Therapy Practitioners provide a critical service to young children with and at risk for disabilities. Occupational Therapy Practitioners use early childhood problem solving models (e.g., Recognition and Response) and integrate their services across three tiers of service. In doing so, they are able to: 1) address the needs of the entire early childhood center or classroom (universal tier), 2) meet the needs of children who are at-risk for disabilities and could benefit from targeted skilled intervention (2nd tier), as well as 3) meet the needs of those children who demonstrate more significant needs and would benefit from intensive services in order to fully access the curriculum and participate fully in the student role (3rd tier). Occupational Therapy is a science-driven profession and practitioners use evidence-based interventions to help children with and at-risk for disabilities do the things that they need and want to do at school. Occupational Therapy Practitioners are highly qualified related service providers who are trained to evaluate and address children’s motor, process, and communication and interaction skills. In addition, Occupational Therapy Practitioners are experts at evaluating the environment and typical performance patterns (i.e., classroom-specific and child-specific habits and routines) that impact a child’s functioning and participation at school. As related service providers, Occupational Therapy Practitioners add value to early childhood teams that focus on including children with all levels of abilities.

492. Bravo! I feel personally and professionally qualified to speak of the lack of, and benefits with inclusive education.

     Thirty years ago as my daughter with intellectual and developmental disabilities approached transition from Part C to Part B services, my school district strongly recommended, actually assumed, the only setting for her services were a self-contained early childhood special education classroom. As I strove to uphold her right to inclusive preschool experiences, I did not realize the intensity or longevity of this endeavor. Nor did I realize the outcomes of having an inclusive education across her school career would hold as much value as it has. For instance, she has a driver’s license and just finished her 1st semester enrolled as ‘audit’ in general ed classes in Community College.

     The reality is that schools are the microcosm of society in which generations practice and define their interactions and skills to become contributing citizens. This is ‘rearing’ is just as important as learning academics. Preschoolers and K-12 students need to share education together seeing and experiencing how accommodations, modifications and adaptions allow for the access, support and participation of those with disabilities and other diversities.

     The specificity and recommendations of the Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs, aptly provides for families to cite and share the federal position on preschool inclusion… and hopefully soon, how their state is addressing the state recommendations.

     Appreciating this opportunity to share my perspective, there are 2 points of adjustment I seek.
     While access is the a necessary step for inclusion, quality of setting and services is paramount as well. Thankfully, the Draft Policy Statement consistently speaks of high quality early childhood . Yet I do have concerns that child care services will need adequate accreditation (NAECY, etc) and special education services to provide for the obtainment of IEP goals. In my personal experiences, getting my daughter in the door of a general ed setting, it was my work to monitor special ed services and gen ed/special ed collaborations that was contingent for good outcomes within each the school year. If the Policy Statement can relieve families of the ‘job’ of daily and/or weekly policing that their child does not get less than appropriate adaptations, it would be a great deed for families and the results of the preschool inclusive child outcomes.

     Inclusive education research speaking to ‘natural proportion’. The federal position that 50% enrollment of preschoolers with and without disabilities is not natural proportion and will likely make the setting a modified segregated classroom. Please reconsider this percentage.

     Finally, please know that as a parent, I have experienced (often repeatedly) EVERY one of the challenges listed on page 5 and 6 of the Draft. THANK YOU for validating my path as not being lived in vain.
     Sandy Ginther

493. I quote here, ” there comes a moment when we realize that what we are advoacating for is more than just accommodations. We are really advocating for our kids quality of life. That is when the moment we realize that we won’t give up.”
     My son is 8 years old and the last two years of his school years since he was KG grade it has been a struggle but nothing. I feel we are still living when kids like my son used to be institutionalized thirty years ago but done in the public school building. There is no facilitated inclusion at all you fight to get a segment of the day to be included with typical kids instead of using that time to do facilitated inclusion it becomes more of a behavioral environment because they are guarded by the support person rather freely playing with their Gen Ed peers. Inclusion is so important for our special needs population but special education use the psychological testing to leave our kids in secluded environment. There are so many of us tired of spending our energy on IEP meeting and passing the prime learning time of our kids. Thanks, Mahlet

494. As a parent of twins classified with Specific Learning Disabilities, I wholeheartedly agree with the writer, Jean Pasternak. I wish my sons had been screened properly, and much sooner. I wish the Special Education at their school would use “evidence-based instruction.”

495. I agree that inclusion is the goal for most preschool children. There are challenges including reduced funding (Head Start was closed in my town) from the federal government. Towns and States are also struggling to find funding. My school has an integrated preschool program though the ratio is below the 50/50%. The students have progressed well over the years and most move on to Kindergarten able to learn alongside typically developing peers. I believe that any unfunded mandates serve to hinder rather that support children with disabilities.

496. As Director of Special Education and supervisor of early childhood programming, I fully believe in and support inclusion. The barriers we see are that the rules that GSRP and Head Start have are contradictory with each other and with special education rules. For example, both Head Start and GSRP can service children across county lines. Special education cannot. Many of those programs have gone full day, and due to our caseload limitations, it is impossible to do with our current funding. We can do better inclusion if we use the new ZS degree, but how to use this to have one teacher for both special education and general education does not match our finance rules. Transportation for families is a nightmare, and sometimes children in the same family have to take a different bus to school depending on what program they are in. We do a LOT of inclusion in our county, but it is harder and harder to keep doing with all the rules. The PQA “dings” classrooms for providing evidence-based strategies for children with special needs. This is causing inclusion to be harder as well. There is also a huge discrepancy in pay between GSRP, Head Start and ECSE classrooms, causing difficulty for co-teaching. I support any and all policy that allows us to have the flexibility with funding, placement, transportation and rules to do the right thing for preschool children. Thank you for considering making these changes!

497. As I write this I am sitting in a country, known for excellent academic standards and achievement scores, that many in the U.S. frequently hold out as the gold standard against which the U.S. should measure student achievement. I have had the opportunity to visit schools for children with disabilities in this country…yes separate schools not inclusive programs.
     My comments:
     The U.S. has to discontinue the schizophrenic policies that ask that our students’ success match that of countries that do not practice inclusion for children with even moderate disabilities and do not count their scores in their ratings…
     The U.S. must realize that LRE is not always full inclusion, that we often slight students with disabilities when we push inclusion at the expense of specialized instruction.
     The U.S. has to realize that without funds dedicated to ideals, the option to attain the ideal is limited or impossible. This would require a reallocation of resources in our country which would require a political will not in evidence in Washington.
     The U.S. needs to recognize that writing a policy is a lovely act of endorsing a concept but without real and genuine support, that’s all it is or can be.
     The U.S. would be wise to note that a lot of the territory within our borders is rural, and rural does not function the same as urban, nor can it, nor should it. As long as the legal requirements for service are limited to children with disabilities and at risk children, there won’t be the expected levels of ‘typical peers’ available from which to create a proportionately inclusive setting as the ‘parents of typical peers’ cannot afford to pay their own way as the shrinking middle class. Nor can small schools provide the space and manpower for the required typical setting when there is an ever fluctuating population of children with disabilities and at risk children that ‘must’ be served by legal mandate.

498. I wholly agree with educating our community’s youngest learners in high quality inclusive early childhood programs. Michigan has taken some bold steps in early childhood education to ensure access for all learners. Many more steps are needed from local district service providers in creating access. A policy statement would set a [high] standard for universal access; so while it may not be necessary to actually do it, it may be necessary to GET people to do it.

499. First – I love this document! I teach inclusion as best practice to my university students studying to be related services providers … then they go out on fieldwork and report predominantly pull out services being delivered. This will help which in turn helps children and youth. Thank you.

     The heading needs to reflect that this is a policy statement on inclusion of children with disabilities in early childhood. Although, it would be a great idea to release a companion that clearly compels inclusion through 21 as it is still common for children to be pulled out for specialized instruction and related services in most school districts in my state. Additionally, I have known children who came from other states where they were educated in segregated schools that only educated children with disabilities. But for this document to be adequately addressing 3-12 rather than just early education, it would need to deliberately and consistently reference older students and their needs. Instead, I like the focus on early childhood which has special circumstances that are addressed in this document. I would suggest making this a series … start with this document, then create a document specific to elementary school, then one for middle school, and finally one for high school and transition.

     A state-level interagency task force may be effective in some states, but in larger states with strong local control, there will need to be more than state-level interagency task forces. For example in Texas, we have Regional Education centers that would stand a better chance of actually making an impact on the ground … those could be linked into a statewide network that tied into the state agencies and stakeholders already referenced on page 7, ADD statewide family networks and family representatives (including families from multiple family organizations may also help with getting information to families, and buy in for inclusion with families who often see pull out supports as preferred).

     I love that it is expressly stated that early interventionists, special educators and related service personnel should deliver services embedded in everyday routines instead of pulling children out. This clear direction is important to reinforce best practice over what has become habitual for many.

     I agree with the concern stated regarding limitations in expertise of general day care staff. The salaries are extremely marginal in my state which makes it unlikely that we will attract highly skilled staff.

     What about giving a broad brush framework to support the practice of inclusion such as the public health model does for Response to Intervention and Integrated Systems Frameworks (ne Positive Behavior Intervention Supports)? I have found that schools that have embraced these early intervention models use staff in ways that are more congruent with LRE and inclusion.

     Under 1. Partner with Families on page 12: I would like to see stronger language directing the state to provide financial support to family run organizations, Statewide Family Networks, PATH and other family run advocacy organizations to enable family to family support and education. It is not enough to “invite to … forums and conferences”. Families have to have the capacity to meaningfully participate and even dissent, which means they need strong, informed and independent leadership and that costs money. The tasks stated in this section can be the deliverables that they provide to the state … they could even serve as the evaluation team for states’ progress on these recommendations.

     I would add to Family Family Resources on page 30 the Statewide Family Networks that exists in many states. Although that funding is tenuous at the moment, those are critical networks that families need to know about and be able to access.

500. As a parent and former teacher, I applaud all that OSEP does to promote inclusion for students with disabilities. Separate is not equal and it is time for the status quo to change. Thank you for leading the way.

501. I myself just finished Edu in early childhood Education with specialty in curriculum and instructional management during the first week of February 2015. Integration of Inclusion program is very crucial for elementary students that have special need, in order to help them with their needs on a daily to day basis. Some of them are with language art barrier, and some migrate to united state with their languages, who are non English speaking at all. This needs must be addresses and solution to it, is to engage them in inclusion program that will help them not to be label as been disable

502. I am the Director of Exceptional Student Services for my district, including all of our preschool 3-5 services. I serve a District in Colorado. We are a state without universal preschool and thus only those students with disabilities or who meet certain at risk factors (up to limited slots available) are funded for preschool. I am in an LEA where our at risk funded pool is far less than our population of children identified with disabilities as we can only serve 46 at-risk students and have well over 90 children with disabilities. This creates adaptive challenges requiring us to provide for tuition-based preschool and work with our community partners. I fully support the inclusionary message, but would urge the Department of Education to define preschool. Utilizing partners such as Head Start or other accredited preschool programs such as those acknowledged by NAEYC is appropriate, however suggesting that “day care” or child care centers offer the same types of educational environments and professional care as licensed preschool programs is a horrible misrepresentation of and EDUCATION in the LRE.

     Our programs offer Department of Education licensed teachers many with a Master’s Degree or higher. Typical daycare or “childcare” providers have very little training, no formal education requirements and absolutely no formal training related to child development. I would really appreciate if the department would define what an “education” in the LRE really is. Preschool programs offer education…” daycare providers” do not and to compare the two is irrational. If this Policy statement is truly designed to improve the quality of early childhood educational experiences rather than simply access to non-disabled peers, then the Department of Education should provide an operational definition reflective of state and federal requirements for programs at least as qualified as Head Start.

     Lastly is is fine and well for the Department to instruct us to work with community preschool providers, however there is nothing in these relationships that can give an LEA the leverage to require private preschool providers to conduct the assessments of young children required by the IDEA. The assessment matrices are complex and difficult requiring extensive training and background in early childhood development. The fidelity of such measures is GREATLY threatened through the utilization of non-qualified setting personnel (such as daycare or childcare centers). If Indicator 7 of the State Performance Plan is of value to the Department (which I believe it is and should be), then setting more rigorous definitions of what constitutes an LRE in the educational environment must be considered. the bottom line is that a Policy statement Aimed at ensuring quality access should do just that and ensure that those settings described as appropriate for the provision of special education​ and related services should reflect the same level of quality targeted by the policy.

503. As a parent of a child with Down syndrome, I strongly support the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education and commend the Departments on their collaboration and excellent policy statement.

     Inclusive early childhood experiences open the doors to inclusion in kindergarten through high school and an inclusive life in the community. The earlier children are in an inclusive learning environment with typical peers, the earlier their needs will be met in all developmental areas.
     The policy statement will ensure that children with disabilities will receive meaningful education alongside their typical peers early on, and ultimately a life of inclusion and acceptance!

     I also agree with Stephanie Lee’s comment that, “In order to implement this policy statement, it will be important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring.
     • Currently an early childhood setting is counted as a regular early childhood program (inclusive) if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”.
     • At this time, if parents are unable to convince the school district to place their child in an inclusive early childhood setting, and pay themselves for their child to attend an inclusive program, the district is still given “credit” in the OSEP 618 Preschool Data Collection for the child attending an early childhood setting in an inclusive (regular education early childhood) program. This is patently unfair and needs to be changed.”

     • I agree with Sally Daminguez as I am also a parent of a child with Down Syndrome. I strongly support this inclusion program as I believe it to be beneficial to our children. DS children has a tendency to imitate and the peer influence in learning will help in a healthy progress in education.

504. IDEA is about meeting the individual needs of each child. That cannot and should not be equated with inclusion. Inclusion, when done well, is indeed the best option for many children. However, if the goal becomes inclusion for all rather than meeting the needs of each child, the spirit of the law is lost and children are harmed. For deaf children the most critical factor in achieving their academic potential is early language development. Deaf infants and toddlers deserve specialized early intervention services and young deaf children deserve linguistically accessible preschools designed to meet their needs. For these children, “inclusion” would, in fact, be isolating, and their ability to succeed academically could be permanently compromised.

505. i support this policy statement and hope that the statement becomes law. i have worked in child care setting were the developmental difference was ignored by the 3 star daycare and the parents. you could address the shame assoicated with learning and development differences, maybe with changing the language? let’s make this policy accountable and transparent for those who develop differnt than the average human!! it’s never to late to get back up again – values.com
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506. Add the bullet below to the first paragraph of the Executive Summary…..This lag in progress is troubling for many reasons:
     • Recent, longitudinal research shows that significant cost savings, as a result of fewer referrals to special education, have been realized when states invest in quality early childhood education based on a study recently published in the Educational Evaluation and Policy Analysis journal. http://www.aera.net/Newsroom/RecentAERAResearch/ImpactofNorthCarolina%E2%80%99sEarlyChildhoodInitiativesonSpecialEducationPlacementsinThirdGrade/tabid/15806/Default.aspx

507. As someone who has worked to promote inclusive early childhood programs since my daughter, who has Down syndrome, attended one of the first Office of Special Education Programs (OSEP)-funded model demonstration inclusive preschools three decades ago, I strongly support the “Draft Policy Statement on Inclusion of Children with Disabilities in Early Childhood Programs” issued by the U.S. Department of Health and Human Services and U.S. Department of Education and commend the Departments on their collaboration and excellent policy statement.
     Inclusive early childhood experiences open the doors to inclusion in kindergarten through high school and an inclusive life in the community. Conversely, barring the door to inclusive early childhood programs often enters a child into a pipeline to separate “life skills classes” in K-12 which many times results in a life of subminimum wage in sheltered workshops or sitting home alone on a parent’s couch.

     This joint policy statement clearly identifies the scientific and legal foundations for early inclusion, identifies the barriers, and recommends specific, common sense strategies for partnering to “build a nationwide culture of inclusion”. The emphasis on applying the policy “to all young children with disabilities, from those with the mildest disabilities, to those with the most significant disabilities.” is particularly important, as children with significant disabilities are often the ones denied inclusive opportunities.

     The policy calls for state policies to “Ensure that the principle of natural proportions guide the design of inclusive early childhood programs.” Then in a footnote says “natural proportions” means the inclusion of children with disabilities in proportion to their presence in the general population.

     In order to implement this policy statement, it will be important to make two changes to the OSEP 618 Data Collection rules for early childhood programs that are used for OSEP monitoring.

     • Currently an early childhood setting is counted as a regular early childhood program (inclusive) if it has more than 50% nondisabled children. The current 50% rule needs to be changed so that only a setting that has a natural proportion of students with disabilities (about 10%) is considered “a regular early childhood program”.

     • At this time, if parents are unable to convince the school district to place their child in an inclusive early childhood setting, and pay themselves for their child to attend an inclusive program, the district is still given “credit” in the OSEP 618 Preschool Data Collection for the child attending an early childhood setting in an inclusive (regular education early childhood) program. This is patently unfair and needs to be changed.

     One of my priorities as OSEP Director was to promote early childhood inclusion through research, model demonstration programs, technical assistance, policy changes and collaboration among agencies. I am delighted to see the progress made in this field and commend HHS and ED on this important joint policy statement.

     • Excellent comments. Inclusion from the beginning is critical to prevent sending our kids into the pipeline of segregated classes.

508. Data from your department has strongly supported very early education for children with intellectual and developmental disabilities and special needs. The Therapeutic Learning Center for Children is a Charter School of the St. Johns County School District in St, Augustine, Florida, and has operated continuously since its founding by The Arc of the St. Johns in 1986. The TLC is renowned for its innovative early intervention, therapeutic education for children three to six years of age. For many years even newborns with special needs were included in the FTE funding, giving them a remarkable head start. Recently, a U.S. Department of Education official informed our TLC that this group of children – birth to pre-three – would no longer be supported by the USDOE or through the local school district. Again, your data fully support the earliest intervention, birth to three, as significant windows of opportunity. Can this one person’s singular interpretation and strong order to discontinue services, be reviewed and funding for services restored?

509. While maintaining special ed students in the least restrictive environment keeps compliance of the mandated Handicap disability laws of 1975, it doesn’t always ensure that they are getting the best instructional treatment. Instructional assistants often time service the other children denying special needs learners much of the attention they require. While classroom size is always capped for this population, and the ratio of students somewhat maintained, referrals to these programs continue to increase, consequently making the setting complex and challenging for everyone.

510. Inclusion is so important to any child, being able to interact with their peers on an even foothold. or a disabled child it is even more imperative. The earlier this can be accomplished, the earlier their needs can be met, enabling them to find that “foothold” with their peers. I wish this would have been something we would have been a part of from the beginning. My child is 8 and I already feel we are far behind. Concerns with cost are also a hindrance for a lot of families and needs to be addressed with a lot more purpose than it is.

511. Inclusion in meaningful programs has to mean that the programs are integrated with typical children. The role modeling and social interactions are so critical for children with disabilities. I would also add to your policy document that the scientific research supports screening as early as 3 years old for dyslexia. All preschool programs should include speech and language therapists, since the preponderance of children classified into special education later in their school lives are for children who fall behind or fail in reading. This is a critical way to reduce the failures of these children, to identify their deficits early and remediate them early with the appropriately trained teachers providing evidence-based instruction. Please include this important point in your policy release. Dyslexics account for 20% of our student populations and many do not progress in either general or special education because the interventions are too late or are inappropriate. EARLY INTERVENTION IS CRITICAL FOR ALL CHILDREN BUT ESPECIALLY THOSE WITH DYSLEXIA, WHO MAKE UP A MAJORITY OF THE CHILDREN IN SPECIAL EDUCATION TODAY.

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