The Netherlands has embarked on a radical reorganisation of the teaching of children with special needs. By the end of the century, if all goes according to plan, far more of these children will be catered for in mainstream schools, while the parents of handicapped children will be free to shop around with their own personalised budget for a customised educational solution for their child.
Special needs institutes are forging closer partnerships with regular schools in their region and from next year will be able to transfer budgets and staff to help keep children with learning difficulties in the mainstream.
Primary teachers are now obliged to draw up learning plans and set targets for children with difficulties.They can be held accountable if the targets are not met.
The education ministry will transfer #163;50 million a year from special to mainstream schools from next year. The aim is to have no more than 2 per cent of all pupils taught in special schools. And it will add on an extra #163;40m to help primary schools retrain staff.
Nevertheless, regional groups of primary and special needs schools will be able to redivide the budget if they fail to meet or exceed the 2 per cent target.
At the same time, the ministry is restructuring schools for physically and mentally handicapped children. Currently there are 11 categories of special schools. These will be grouped into four types, dropping the segregation policy whereby, for example, a child who is hard of hearing is not able to attend a school for the deaf.
Each child will have his or her own "action plan", drawn up each year in consultation with parents. Schools will be responsible for meeting the conditions set down in these charters. Parents, who will be allotted a budget for their child, can withhold the money until they agree with the plan. National criteria will also be drawn up for assessing a child's needs.
"In the past too many schools were referring children with learning difficulties too easily to special needs institutes. The child was placed under care. Now we are saying move the care to the child, even if this leads to catering for a handicapped child at a regular school," said Brenda Fidder, a ministry spokeswoman.
However, remedial teachers such as Emmy Kaas in Amsterdam say most primary teachers are not trained to deal with children with severe learning difficulties. "The training for a remedial teacher and for special needs teacher are worlds apart. And it seems that children who initially have been kept at normal schools in the end find their way back to special needs," she said.
Mainstream teachers are getting better at spotting learning difficulties, Kaas conceded. But she added that the government was not adequately funding the extra care and facilities necessary to properly accommodate more special needs children in mainstream schools.
The integration of disabled children into mainstream schools has become one of the most divisive issues in Australian education.
Some schools are refusing to admit children with particular mental or physical disabilities, saying they have not been given enough government help.
Parents and teachers have clashed over the issue with some parents turning to the courts to force schools to accept their child. The pitting of parent against school has led to bitterness, with the child the one who usually suffers.
Parents of disabled children have fought for years to have their children educated in mainstream classrooms, rather than segregated in special settings.
This is despite the fact that all states and territories have special schools - many run by charities - for children who are blind or deaf or who have other physical and mental disabilities. Such schools are often lavishly equipped and offer small classes run by specialist teachers, with well-trained support staff.
Yet many parents believe there is a stigma associated with such schools and say they are entitled to access to mainstream classrooms.
In Victoria, South Australia and the Australian Capital Territory, this has long been accepted. There, government policy is for mainstream schools to admit disabled children. Schools have complied because they have been given at least some resources - especially expert teaching aides.
But elsewhere across Australia, teachers have been reluctant to enrol disabled children without any additional help.
According to the Australian Education Union, state education ministries too often leave the issue to be resolved at the local level, rather than making a commitment to integration and backing that with money. The union has called for standards to apply to the integration of disabled children.
Commenting on those cases where parents have been refused access to mainstream schools and have taken the matter to the courts, the union said: "In all circumstances, this requires that there be victims. In most cases those victims are the students themselves and the education workers that teach them.
"For these people, there is considerable and often excessive stress and trauma involved in the process. For the teachers involved, there may well be long-term personal and career consequences."
The issue of children with emotional or behavioural problems is just as, if not more, complicated. Schools can suspend pupils who attack staff or other children, but are supposed to offer problem children psychological help beforehand. In many cases this does not happen.
Integration in Italy is 20 years old. Special schools disappeared almost overnight in 1977 when legislation provided for the integration of children with special needs into mainstream education.
Almost inevitably, the schools were not ready in time, lacking facilities and trained staff, and it was not until the mid-Eighties that training courses were organised.
Today there are 110, 000 statemented children in mainstream state education (2 per cent of the total school population), most of them in the compulsory primary and lower secondary sectors.
However, an increasing number of 14-year-olds with special needs now go on to scuola superiore (with a 10 per cent rise in enrolments in 199697 over the previous year), which seems to suggest that integration is working.
Depending on the nature of a pupil's learning difficulty, he or she is assigned to a "support" teacher for anything from four hours per week to a full timetable.
Wherever possible this teacher stays with the pupil in the classroom, helping them to participate in class activities.
The teacher may need to produce special materials, and at exam time, special tests which parallel those of the rest of the class, but which are within reach of the individual. A policy of positive discriminati on means that no reference to "simplified" tests appears on the child's public exam certificates.
While the number of special needs pupils has remained stable over the past 10 years, the number of teachers has continued to grow.
One in 14 teachers is now a specialist in sostegno (support), and special needs has become a classic route back into work for supernumerary class teachers.
Against a backdrop of falling rolls, disappearing classes, and schools closing down, special needs is the most obvious way of absorbing teachers who would otherwise lose their jobs.
This year the government is financing a major project to retrain supernumerary teachers to work with special needs children.
But supporters of integration would argue that the best way to measure the success of their policy is not through the steadily improving pupil-teacher ratio (which now stands at 2:1) or the slow but sure provision of wheelchair access to schools. Rather it is that a generation has now grown up in Italy believing that children with special needs do not have to be sent to special schools.
American law requires a "free and appropriate education" for children with special needs, in the "least restrictive environment". In a litigious society, this wording has helped to turn special needs education into a bonanza for lawyers.
Two issues have proved a political and legal minefield. The first, predictably, is how far disabled children should be integrated into mainstream classes. The second is the huge number of children now classed as "learning disabled" without an obvious mental or physical impairment.
More than five million children in the US, about 10 per cent of the public school population of 44 million, are officially diagnosed as having disabilities. Of this huge number, about half, or 2. 6 million children, are "learning disabled". About half a million suffer "severe emotional disturbance", a million or more from speech or language impairment, and a further 500,000 have "mental retardation". The remainder suffer serious disabilities, from autism to brain injury and blindness.
The US spends about $32 billion (#163;20m) a year on their education. While the federal government lays down the ground rules, the individual states provide the lion's share of funding. There are many complaints that despite good intentions the programmes have never been funded properly.
The major piece of legislation in the area, the Individuals with Disabilities Education (IDE) Act, was redrafted this year after a political battle. It pitted advocates for the disabled pressing for greater access against conservatives citing costs, and teachers worried about disrupted classes.
Nearly three-quart ers of all children with disabilities are taught in mainstream classes for part of the day, it is reported, though only about a third spend more than 80 per cent of their time in such classes.
US policy has rested on the "continuum of placements". After the child is evaluated by a team that typically consists of a psychologist, a social worker, a teacher and a doctor, options run from a regular class through resource rooms, separate classrooms, special education centres, residential institutions, and hospitalisa tion.
While states typically have separate schools for blind, deaf, and severely emotionally impaired children, policies on admissions vary. States regularly face lawsuits from parents either determined that their children stay in the mainstream or demanding greater resources, and courts have jumped both ways. School districts have sometimes been accused of integrating disabled children to save money.
In the rewriting of the IDE Act, some concessions were made to teachers. "Stay put" provisions meant a disabled child stayed in a class while his or her placement was challenged in the courts. That rule has been relaxed where a pupil is found in possession of weapons or drugs.
The "learning disabled" issue remains controversial. The numbers of children diagnosed this way, with everything from dyslexia to attention deficit disorder, has gone from 800,000 in 1977 to 2.6 million today. Critics say that the label is now applied to lazy, below-average, or poorly-motivated children with pushy parents or schools seeking more state funding.
The argument also is beginning to be heard that the huge growth in dyslexia and other problems associated with poor reading may be laid partly at the door of "whole-language learning". This reading method was adopted in American schools as an alternative to phonics, but is now widely criticised.