Back in 2021, Susan Book did not know what she was going to do. Her son in the 4th grade in the US (equivalent to Year 5 in England), who was diagnosed with autism spectrum disorder, had been removed from his mainstream classroom in North Carolina. He was put on a programme of “Home Hospital” education, which meant he would receive about an hour of instruction per day from a teacher visiting his home, for an unspecified and unlimited amount of time.

His removal from school was due to behaviour challenges - but neither the school nor the district (local authority) had any sort of plan on how to help him improve, and they didn’t have the resources to provide a one-to-one teaching assistant to help him safely return to school.

“We needed help immediately - we couldn’t wait,” Book says. “But the biggest problem was that schools were just not willing to take him.”

Desperate for some kind of solution, her son’s private therapist mentioned the Wright School, an alternative provision funded by the North Carolina Department of Health and Human Services, focused on rehabilitating students with behavioural and mental health challenges so they could return to mainstream classrooms.

Book enrolled her son at the school after a lengthy referral process, and his six months there, continuing learning and receiving multiple therapies, changed his life, she says. He returned to mainstream school with a dedicated teaching assistant the next year, and has had a much more successful school experience ever since.

But Book understands her son’s success story is rare, and that her full-time advocacy on his behalf is not something all parents can do. There are not enough alternative-provision or special-school placements in North Carolina for all the students who need them; waiting lists can last for months or years. And many local schools have been struggling for years to provide the necessary services to students who qualify for support around special educational needs and disabilities (SEND), or what the US calls “special education”.

Most often, families like Book’s have to figure out a plan of their own.

“I would love to replicate [Wright School], and how they do things for disability students, all over the place, but no one wants to spend that type of funds,” says Book, who is the engagement coordinator for advocacy group Every Child North Carolina. “It’s a hidden crisis: we have devised a system where we are not speaking as one. We fight these battles one by one.”

Many elements of Book’s story will ring true for teachers and families of children with SEND in England. Both here and in the US, the number of students needing special-education services is growing, while resources strain to catch up.

SEND and the value of inclusion

Yet the two countries’ responses to the problem have been wildly different: England is currently pursuing policies of greater inclusion, while the US questions inclusion altogether.

So, what does the picture look like on either side of the Atlantic? And what does a comparison of the two countries tell us about the value of full inclusion, and how committed we should be to it as a policy?

Students receiving special-education services currently make up about 15 per cent of the US K-12 (Years 1-13) school population, growing from about 6.4 million students in 2012 to 7.3 million in 2022, according to the most recent available data.

In England, an even larger proportion of students currently receive some form of SEND provision. Between 2015 and 2024, the number of students with the highest levels of need who receive education, health and care plans nearly doubled; the proportion of students receiving SEND provision without an EHCP rose in that time from 11.6 per cent to 13.6 per cent. The two groups put together mean that 18 per cent, or nearly a fifth of students, need interventions.

It’s important to note that students who receive this support vary widely in both diagnosis and need, and include those with learning challenges like dyslexia or dyscalculia; those with physical disabilities like blindness or deafness; and autistic pupils and those with Down’s syndrome.

But in both countries, as the number of students with special educational needs continues to climb, the number of qualified teachers and specialists is shrinking. According to the US’ Council for Exceptional Children non-profit, 39 states report special-education teacher shortages, and 65 per cent of public schools report being understaffed for special education.

There’s also a lack of specialist provision across England, according to Margaret Mulholland, SEND and inclusion specialist for the Association of School and College Leaders.

“We’re really short on access to educational psychologists, speech therapists and occupational therapists,” Mulholland says. “We also don’t have the specialist settings that many would argue we currently need.”

Increase in need, along with better diagnosis capabilities, means more students qualify for support, yet there is a lack of help available. It’s a situation that England has declared a “crisis”. After evidence emerged that most schools don’t have the staff needed to help children with SEND, and that there aren’t enough special-school places for children who need them, earlier this year the Department for Education appointed a special commission of 19 leaders across government and education to try to solve the problem, with a focus on making mainstream schools more inclusive for students with SEND.

While a similar shortage of placements and qualified teachers exists in the States, no crisis has been declared and no special committee assembled. Instead, in many ways, the opposite has happened - Department of Education cuts under the second Trump administration threaten what funding does exist to help students with disabilities.

Big disagreements on how best to help students

And when it comes to ideas about the type of provision that best supports students with SEND, the two countries are also moving in very different directions.

England’s current Labour government, concerned in part by the sector’s increasing reliance on independent special schools, is pushing to include more students with SEND in mainstream schools. The DfE has said that making mainstream schools more accessible to all is a key piece of its SEND reform agenda. To that end, the Inclusion in Practice commission has already called for evidence and best practices, including getting to know student needs early and employing evidence-informed instructional approaches. Ofsted, meanwhile, is overhauling how schools are inspected around SEND.

It’s worth noting that while the sector generally supports inclusion in principle, some have questioned the nature of Labour’s push. Special-school leaders, for example, have pointed to the fact that their schools already face demand for places that far outstrips supply, and have raised concerns about whether the students requiring those places could really have their needs met most effectively in mainstream classrooms.

But while England strengthens its commitment to full inclusion, the US might be rethinking it. Conducted by Douglas Fuchs, emeritus Nicholas Hobbs Chair of Special Education and Human Development at Vanderbilt University, a recent analysis of about 50 years of research has called into question the idea that “full inclusion” in mainstream classrooms is always what’s best for all students with SEND.

According to Fuchs, a significant number of studies examining whether SEND students perform better in mainstream classrooms are fundamentally flawed. Many of these “efficacy studies” compare students who joined mainstream classrooms to those who continue in special provision, which could lead to misleading conclusions, Fuchs says.

It could be that students who joined mainstream classrooms did so because their teachers felt confident they could succeed there, Fuchs explains, while the same was not felt about the students who continued in special provision. “So it doesn’t tell us anything about the quality of the general-education classroom versus that of the special classroom,” Fuchs says. “When it came to the kids who were spending less time in general education, educators understood that they needed extra support.”

More recent randomised controlled trial studies looking at inclusion give a slightly clearer picture. When intensive interventions for students with SEND that focus on small group instruction outside mainstream classrooms are tested against students being educated entirely in mainstream, high-quality research often shows the intervention students perform better academically than the “full inclusion” students, Fuchs says.

This raises some key questions for policymakers, he continues: “When it comes to thinking about a policy of placing these kids, do we rely on the efficacy studies and the correlational studies that are fundamentally flawed? Or are we more persuaded by the later studies, which are all randomised controlled trials?”

This doesn’t mean that inclusion isn’t beneficial to students, Fuchs is quick to add. Some families want their students in mainstream classrooms for social reasons, to learn together with peers, and they should be allowed to choose. But families (and policymakers) who want academic acceleration for their children need to consider the more methodologically sound evidence. Some students do well in mainstream classrooms, but many more are struggling, he says.

Ultimately, in both countries, the discussion around inclusion needs to be more expansive, says Rob Webster, a researcher at the Institute for Lifecourse Development, University of Greenwich, and author of The Inclusion Illusion. He believes it’s important that debates about how best to meet the needs of students with SEND do not “position other motivations and outcomes as secondary or subservient to academic outcomes”.

To do so is to misunderstand what inclusion is really about, he argues. “Inclusion is not an instructional strategy for maximising outcomes. It is a principle that guides and defines what your education system is or isn’t. It’s an equity-of-education thing.”

Solutions for complex systems

When it comes to solutions, what’s next for these two countries and their varying approaches to the common problems they face? And how might their different levels of commitment to inclusion shape the next steps they take?

The US system of special education is made to be somewhat inflexible, bound by federal law to protect students. The word “inclusion” isn’t mentioned in the Individuals with Disabilities Education Act, says researcher Zach Rosetti, an assistant professor of special education at Boston University. Schools are required instead to provide what’s known as “the least restrictive environment”, which, says Rosetti, is “interpretable enough, with enough grey area, that it’s been misinterpreted constantly”.

As a result, provisions for special education vary widely from state to state, Rosetti continues. Only 5 per cent of New Jersey’s students with SEND are fully included in mainstream schools, for example, while in other states like Vermont, the numbers are much higher.

This picture is complicated by recent budget cuts and president Trump’s March executive order demanding the entire Department of Education be dissolved, which has caused chaos in the special-education community.

Experts themselves are still unclear what many of the recent decisions mean for special-education students. While the administration has promised that funding for special education will remain, and perhaps be even more flexible in how funds can be spent, many worry that the cuts may ultimately hurt any attempt at reform.

England, meanwhile, is arguably in a stronger position to make positive changes right now - including turning to other countries for possible solutions. The Nuffield-funded ScopeSEND project, launched in 2024, is examining how SEND systems in Ireland, Australia, Switzerland, Belgium, Finland and the four countries of the UK compare on inclusion from the point of view of people who participate in the system - namely parents, students and professionals.

Lead researcher Susana Castro-Kemp says the systematic review has already led to key insights - including, maybe most importantly, the fact that no SEND system is perfect. “People have the expectation that the introduction of a new policy is going to solve all the problems, but this is not an issue that can be ‘solved’, and we cannot have a perfect inclusion system. Inclusion is a process,” she says.

People clearly have more positive interactions with the system in certain jurisdictions, such as Scotland and Finland, compared with places such as England, where people reported more negative reactions. “Actually, the language used is quite strong [in England]. Parents [feel they are] having to ‘fight the system’; they’re using words like ‘fight’ and ‘battle’,’” Castro-Kemp says.

“We cannot have a perfect inclusion system - inclusion is a process”

Countries such as Finland have focused less on diagnosis and leaned into early screening and intervention instead, often regardless of diagnosis. “That investment in early intervention means that resources are in place from a very early age,” she says. “When you get to the age of 7, 8, 9 - which is when the demands of schooling often lead to the demand for a diagnosis - often you don’t need one. Or even if you do have a diagnosis, that doesn’t change anything because the support is already in place.”

Some English schools are already incorporating similar ideas. Early intervention and the careful targeting of resources are important at Greenshaw Learning Trust, which oversees more than 30 schools across the country. “You don’t want any child to leave primary unable to read, so being able to really flex the resources you’ve got is key,” says Amelie Thompson, assistant director of education (SEND and special provision).

The trust also focuses on the universal offer, with strong instruction and routines to help all students thrive, Thompson says.

To do SEND provision well, several different systems have to work together. “A really systemic and systematic approach builds that capacity to be able to tighten that support around those few individuals who might need it at different times,” Thompson says.

“As we go in and work with schools, we are being really deliberate and intentional about inclusion being a process - it’s something dynamic, not a static end point that we get to and say, ‘OK, this job is done.’”

Ultimately, while England’s SEND system might still be in “crisis”, international comparison suggests that the country’s moves to acknowledge the problem - and begin the search for answers - have already put it a step ahead of the US, where, as experts point out, the issues go far beyond SEND.

“If it weren’t for all the craziness [in Washington] that’s engulfing us, there might be greater attention to the fact that K-12 education is in a very deep crisis,” says Fuchs. “I’m not overstating the case. There aren’t enough teachers for classrooms - many schools are way behind in terms of what they need in terms of just numbers - and then how many of them are certified? How many have been trained and have the right degrees? The picture is abysmal.”

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