Introducing Bruner: A Guide for Practitioners and Students
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By Kyle Robinson and Dr. Nancy L. HutchinsonThe expression “tiered approaches” has been used in two distinct but related ways with reference to the education of students with learning disabilities (LDs). Each of these approaches is described below.First, the Ontario Ministry of Education has advocated the use of what it calls the Tiered Approach to Early Identification and Intervention in both Education for All (2005) and Learning for All (2013) as a method of instruction and early identification of students with exceptionalities. Specifically, the Ministry defines it as “a systematic approach to providing high-quality, evidence-based assessment and instruction and appropriate interventions that respond to students’ individual needs” (2005, p. 22). The Ministry has devised a three-tier system, as shown in Figure 1. This is often referred to as Response to Intervention (RTI) outside of Ontario, a process whereby sound, evidence-based, differentiated teaching is used to instruct all students, but students who do not respond to this instruction, or who need further help, are moved up through a series of increasingly intensive interventions.The second ‘tiered approach’ is used when designing classroom lessons and assessments. Students are grouped and then taught and assessed on different levels of content on the same general curricular topic, in fluid groupings. Students may choose or teachers may assign students to one of a number of levels of challenge in classroom learning tasks and associated assessment.The typical method of identifying students with LDs is often referred to as a “wait to fail” model – where referrals for additional instruction or educational support are only provided after a student has failed to learn. This method is prone to several disadvantages, which include “relatively late identification for students who have special needs; imprecise screening through teacher observation; false negatives (i.e., unidentified students) who are not provided necessary services or provided services too late; and the use of identification measures that are not linked to instruction” (Vaughn & Fuchs, 2003, p. 139). Through the Tiered Approach to Intervention, students are assessed based on risk, rather than deficit, meaning that intervention is proactive rather than reactive. Vaughn and Fuchs (2003) discuss several other benefits to this proactive approach, including early identification of students with LDs, a reduction in identification bias, and a strong focus on student outcomes.The most common form of the Tiered Approach to Intervention is called Response to Intervention (RTI), and is a process whereby all students are taught using sound, evidence-based teaching practices designed to allow all students to succeed. If students fail to learn a particular concept, or struggle to learn it, they may be moved to Tier 2, which is intense and focused small group instruction. If a student grasps the concept, they can return to the general Tier 1 learning environment, but students who continue to fail to make progress are moved to Tier 3. This last Tier is typically comprised of individual instruction, “which may be special education in some areas” (Mastroppieri, Scruggs, Hauth, & Allen-Bronaugh, 2012, p. 231).The Tiered Approach championed by the Ontario Government is mainly comprised of methods that would be considered interventions. The scientific studies cited are intervention-based and, as Mattatall (2008) suggests, Ontario documents use “more [of] the language and approach of RTI” than most provinces. Furthermore, “it appears that Ontario leads the rest of Canada in promoting a tiered format” to instruction and intervention” (Matattall, 2008, p. 15).Sharon Vaughn and her colleagues have conducted the majority of research cited by the Ontario Ministry of Education documents in support of the use of tiered instruction. Vaughn, Linan-Thompson and Hickman (2003) showed that using a tiered approach to instruction could help improve student’s word attack (ability to decode words), fluency (ability to read rapidly and accurately), and comprehension (ability to understand what is read. They also found that the majority of students met grade expectations following tier two.In a study from the same year Vaughn et al. (2003c) looked at how the ratio of teachers to students impacts instruction for students with reading disabilities. They reported that the lower the ratio, the higher the scores on typical reading measures. However, there was no significant difference between a 1:3 ratio teachers to students and a 1:1 ratio. This evidence strongly suggests that the movement to a smaller group increases a student’s ability to learn, especially for those at risk of a reading disability.A similar study was conducted by O’Connor (2000), with Kindergarten students at risk for reading disabilities. O’Connor suggests that starting an intense process of tiered intervention in “kindergarten might ‘jump-start’ these [reading] skills among children who lacked exposure and opportunity and assist in identifying children who may be more ‘truly’ reading disabled” (p. 44). Essentially, O’Connor was looking to reduce the number of students being identified as having reading disabilities, when their low abilities in reading stemmed from environmental, rather than developmental, issues. The intense intervention did not result in a decrease in the proportion of students later identified for special education needs; however, there was a decline in reading failure rates. Interestingly, this finding contradicts the results from a Canadian study. Citing reports from the National Reading Panel (2000), Barnes and Wade-Wooley (2007) suggest that “up to 70% of later diagnosed LDs can be prevented with a combination of early screening, progress monitoring, and teaching that is responsive to emerging learning problems” (p. 10) – which are all contained within the Tiered Approach to Intervention.Whether a tiered approach to intervention decreases identification of LDs or not, these studies suggest that an increasing intensity of instruction based on student needs creates a positive learning environment where students can continue to learn in their regular classroom environment. While the studies above focused mainly on interventions related to reading fluency and comprehension, the tiered approach can be used in many classes when teaching any concepts or skills with which students struggle. Several studies (e.g., Fuchs, Fuchs, & Prentice, 2004; Fuchs et. Al., 2005) have shown that RTI and, by extension, the tiered approach to intervention, has been useful in teaching number sense, word problems, and mathematical operations.The previously discussed studies have been combined to create a classroom model for tiered instruction that could be implemented in a school board. Although various researchers and texts use different language, the tiered approach (OME, 2005; OME, 2013), progress monitoring (Hutchinson, 2013), and RTI (Vaughn & Fuchs, 2003) embody similar teaching strategies. The tiered system described below is heavily inspired by the method briefly laid out in Education for All (2005), and later refined as part of Learning for All (2013). A basic model of this system is shown in Figure 1.Figure 1. The Tiered Approach to Intervention; commonly referred to as Response to Intervention (RTI).Adapted from: Ontario Ministry of Education, 2011; Matattall, 2008; Katz, 2012.Tier 1: Universal Programming. Tier 1 is the typical classroom environment. The teaching strategies and instruction used here reflect both methods of differentiated instruction and universal design for learning. Classes are structured and planned to reach every student in the class, regardless of exceptionality, and the curriculum goals are not modified. Throughout this process, the classroom teacher monitors the progress of students and notes students who are struggling and falling behind their peers.There are many different methods to introduce differentiated instruction (DI) into the classroom. Nancy Hutchinson (2014) offers 10 introductory principles of DI to guide teachers:(Adapted from Hutchinson, 2014, p. 8)Education for All (Ontario Ministry of Education, 2005) suggests many of the same practices and includes ways in which a teacher might adapt these for specific use in the classroom. When these practices are used effectively, most students learn at a rate that is typical for their developmental stage in Tier 1. Shapiro (2014) suggests that up to 80 percent of students should reach successful levels of learning through Tier 1 support.Tier 2: Targeted Group Interventions. Once the teacher has gathered enough evidence to show that a student or a number of students is struggling to learn, they are moved to Tier 2. Tier 2 includes more intensive, systematic instruction, often tailored towards a small group of students demonstrating similar difficulties. This could include extra help during school or after school, extra homework, varied readings, or co-teaching support. This Tier does not typically involve removal from the regular classroom environment; rather “the interventions take place in the original classroom, over a set period of time, with different students involved, depending on the skill or concept being addressed” (Katz, 2012, p. 139). Results of instruction and assessment are closely monitored. Once an individual or group of students has mastered the concept or skill, they can return to instruction at Tier 1 for future concepts and skills.Hutchinson (2013) provides an example of Tier 2 instruction: “if some students in a Grade 1 class are not learning to read with their peers they could be taught in a small group of two to five; this often takes place for ten to twenty weeks for forty-five minutes on most days” (p. 9). The extra instruction provided to students in this tier is not a substitute for the universal programming instruction provided in Tier 1. Rather, it is supplementary to the base instruction (OME, 2005). This means students should essentially be receiving double instruction – some as part of the full classroom, and some in a small group. This tier will, on average, account for an additional 15% of students learning (Shapiro, 2014).Tier 3: Intensive Individual Interventions. If students are still struggling with material after a period of group instruction at Tier 2, they are moved to Tier 3. This tier involves increased intensity (more instructional time, smaller group size or individual instruction) and increased explicitness (more focus on teaching specific skills). At this level, resources from outside the classroom are brought in to facilitate the learning. This could include a special education teacher, resource room teacher, or administrator. Instruction is tailored to the specific student, and is “precise and personalized” (OME, 2013, p. 24). Interventions in the third tier could also include “instruction in learning strategies provided outside the content area classroom that will enable students to learn independently once they are in content area classes” (Cook & Tankersley, 2013, p. 101). Learning strategies could be broad such as note taking, time management, personal management, or specific to a subject like reading.Often, students who struggle enough in their learning to make it to this tier are referred for psycho-educational testing – screening for potential learning disabilities or other exceptionalities. Students who are struggling enough to move to this tier are also usually given an Individual Education Plan (IEP), and initial steps may be taken towards establishing an Identification, Placement and Review Committee (IPRC).Education for All (Ontario Ministry of Education, 2005), calls for teachers to receive “adequate professional development in teacher-based assessment practices, progress monitoring, and intervention strategies for students with special needs” (OME, 2005, p. 60). This tiered approach also requires the participation of the entire school community (administration, special educators, and regular classroom teachers) for its implementation. The separation of duties between classroom teachers and special educators – “in which universal [tier 1] and group [tier 2] interventions become the sole concern of general education and individualized supports [tier 3] the concern of special education” (Agran, Brown, Hughes, Quirk, & Ryndak, 2014, p.109) – is a concern and arises when all school roles are not involved in the tiered approach to intervention. Teachers, administrators, and special educators need to be involved in each step of the process. Thus schools or school boards typically take the initiative to implement a system of RTI or tiered instruction, rather than classroom teachers.There are still lots of questions to be asked about the implementation of the Tiered Approach, to Intervention. For example, Fuchs and Deshler (2007) discuss the potential limitations of RTI in a secondary school setting. How do teachers successfully implement RTI for a Grade 10 student who is reading at a Grade 2 level (Fuchs & Deshler, 2007)? As well, while reading has been the primary focus of RTI studies (e.g., O’Connor, 2000; Vaughn, Linan-Thompson and Hickman, 2003; Vaughn et al., 2003c) and math (e.g., Fuchs, Fuchs, & Prentice, 2004; Fuchs et. al, 2005), how is RTI successfully implemented for other subjects, such as social sciences? And how can teachers take the initiative to implement this approach if it requires full-school cooperation? However, individual teachers can implement a second tiered approach, as a means of providing differentiated instruction, without outside help.Ontario Ministry of Education. (2005). Education for All: The report of the expert panel on literacy and numeracy instruction for students with special education needs, Kindergarten to Grade 6. Toronto, Ontario: Queen’s Printer for Ontario. Access at: http://www.edu.gov.on.ca/eng/document/reports/speced/panel/speced.pdfThe first place that teachers should go to learn about The Tiered Approach. To read about Ontario’s approach to RTI, see page 60. Chapter 2, on planning for inclusion, also provides excellent ideas on Tier 1 teaching strategies.Ontario Ministry of Education. (2013). Learning for all: A guide to effective assessment and instruction for all students, Kindergarten to Grade 12. Toronto, ON: Queen’s Printer for Ontario. Access at: http://www.edu.gov.on.ca/eng/general/elemsec/speced/LearningforAll2013.pdfThis document builds upon the work of the earlier Education for All (2005). It includes diagrams and helpful hints at how The Tiered Approach could be adapted for secondary schools.Kari Draper, Learning Support Teacher at Ottawa-Carlton District School Board Access at: http://www.scribd.com/Uruz86Draper provides downloadable documents, charts, and calendars to help classroom teachers monitor the progress of their students when teaching using The Tiered Approach to Interventions in Ontario schools.The RTI Action Network: A Program of the National Center for Learning Disabilities. http://www.rtinetwork.org/This provides excellent articles and further ideas on how to implement RTI in a variety of ways. Content is geared towards the American school system, but can easily be adapted to fit the Ontario curriculum.DeRuvo, S. L. (2010). The essential guide to RTI: An integrated, evidence-based approach. San Francisco, CA: Jossey-Bass.Although American, this teacher guide to RTI, part of a teaching series, provides excellent, clear ways to implement RTI in classrooms from Kindergarten to Grade 12. It also has easily photo-copied progress reports, student tracking forms, collaboration planning forms, and lesson plan templates to help teachers easily monitor student progress through the tiered approach. Best practice for RTI: Differentiated reading instruction for all students (tier 1). Access at: http://www.readingrockets.org/article/30672This article, from Reading Rockets, provides examples of how teachers might implement RTI when teaching reading in the early grades (1 – 3). Solutions for common “roadblocks” (or problems) are also discussed.How can tier 3 be conceptualized in the RTI approach? Access at: http://iris.peabody.vanderbilt.edu/module/rti05-tier3/cresource/how-can-tier-3-intervention-be-conceptualized-in-the-rti-approach/rti_tier3_03/#contentTeachers looking for more information on how Tier 3 (Intensive Individual Interventions) might fit into their use of the Tiered Approach to Intervention should check out this resource, which includes an interview with Dr. Lynn Fuchs, one of the preeminent scholars on RtI in the United States. Other pages help to distinguish between possible interventions provided in Tier 2 and 3.The tiered approach to classroom tasks and classroom assessment enables the teacher to provide differentiated instruction (DI) within the individual classroom, by offering opportunities for students to work at varying levels on tasks (and the associated assessment) drawn from the curriculum. This approach conforms to many of the common aspects of universal design for learning (UDL) as well as many of the goals set out in Growing Success (2008).“Tiering” (for tasks and assessment) can come in two forms – student choice and teacher assigned. Student choice, sometimes referred to as challenge by choice, is an approach to assessment whereby teachers create a series of different tasks and accompanying assessments designed to evaluate the same skill or concept – and allow students to choose. Servillo (2009) suggests that choice is a method to motivate reading, especially for students considered at risk or who have LDs in reading. Servillio describes the creation of a reading activity and assessment that involves three difficulty levels of tasks, in two different areas of the curriculum. Students then choose one item from each difficulty level and area of the curriculum. When practicing comprehension and personal connection to a text, the teacher allows students to read the material in three ways; they may read the chapter silently alone, read every other page aloud with a partner, or follow along as they listen to an audio recording of the chapter. This helps students of various reading abilities to acquire and retain the information that is required to complete the next step, namely comprehension and personal connection questions.Similar choices are given in the subsequent assessment. To show they comprehended the text, students can do one of three tasks: write answers to the questions they asked themselves as they read the chapter, summarize what was read (or heard) in the chapter, or use an advanced organizer to create a timeline of events for the chapter. This allows students of various levels of competence in reading to complete meaningful learning tasks and to demonstrate what they have learned in a way that works for them.Tiered instruction and assessment can also prove useful in science, where Adams and Pierce (2003) suggest a process of tiered instruction and assessment that could differentiate learning in one of three ways: “content (what you want the students to learn); process (the way students make sense out of the content); or product (the outcome at the end of a lesson, lesson set, or unit—often a project)” (p. 30). Unlike Servillo’s (2009) student-choice model, Adams and Pierce suggest teacher-assigned grouping of various sizes to meet the learning needs of each student. Groups can be formed based on one of three characteristics: readiness level (below, at, or above grade level), learning profile (auditory, visual, or kinesthetic), or student interest. For example, students grouped together due to a low readiness level “might work very concretely by investigating the kinds of objects that a magnet can attract … A tier of students at a more advanced level of readiness, however, might investigate whether the size of a magnet affects its strength, a more abstract concept” (Adams & Pierce, p. 32). To avoid stigma associated with being a member of a lower level group, Adams and Pierce recommend that teachers consistently change the way students are grouped, using all three sets of characteristics laid out above.There are times when grouping by readiness level is necessary. This is typically seen when teachers need to assign appropriate level texts to students grouped based on reading ability. Selecting more readable, or lower than grade level texts, is a difficult task. As students age, the content and look of texts tend to change as well. For example, when one compares the look of a young adult book to a book for pre-teens, there is an immediate difference in both content and overall look. Books assigned to the low-readiness group can look or sound childish, turning students who already have reading difficulties away from reading. It is important, then, to look for texts that are hi-low, that is, high in interest, and low in readability. ORCA Publishers (click here to access the ORCA Publishers website) specializes in such texts; for example, providing texts that have young-adult stories, but are written at a much lower reading level.Providing students with lower-level texts is not always appropriate, nor necessary. The advancement of assistive technology in the classroom has made it possible for students to read and comprehend grade-level materials. One such device, the ClassMate Reader, is a portable text reader “designed to promote reading and learning independence” (Floyd & Judge, 2012, p. 52). This portable device reads the material aloud while highlighting the individual words and phrases in order for the student to follow along. Studying the effects of the device on student’s reading comprehension, Floyd and Judge found that students were able to increase their average score on a basic comprehension test while using the device. Some students more than tripled their score, with one student going from 20% without the device, to 80% with it. While the ClassMate Reader is a portable handheld device, many boards within Ontario have access to similar programs on their school’s desktop and laptop computers. Computer programs such as Read&Write Gold (click here to access the Read&Write Gold website) and Kurzweil (click here to access the Kurzweil website) provide the same functions as ClassMate Reader, and often have free trial periods.Assistive technology can also help increase a student’s reading fluency. READ 180, from Scholastic, Inc., is one of the few assistive technology programs specifically designed for older students, specifically those in Grades 4 – 12. Using a blended classroom environment (part online, part in class) students learn about a variety of topics while reading ebooks (some books are also available as paperbacks as well). Students track difficulties with the software, using text-to-speech programs (like those seen in the previous paragraph) for particularly difficult segments. After reading, the software immediately provides instruction on key concepts or words the student struggled with. The online student dashboard monitors student progress, and outputs it in two ways. For students, it uses “research-based gaming behaviors,” turning the process of reading into a game – students are able to track their “streaks and trophies earned” (Read 180, 2013). Teachers receive student performance data, allowing for targeted interventions on areas individual students need most. It also allows teachers to group students for differentiated instruction, while providing lesson-planning tools. The program is a success, with one school board in the United States seeing “significant gains in reading fluency and comprehension for special education students” (Hasselbring & Bausch, 2005, p. 74). Perhaps the most exciting part about READ 180 are it’s long term effects – Palmer (2003) found that “18 percent of the students in the study no longer required special education services for reading after one year of intervention” (as cited in Hasselbring & Bausch, 2005, p. 74). Although the system is currently based on American Common Core standards, it can still be used in Canada as a powerful monitoring tool.Carol Tomlinson, a leading expert on differentiation, refers to this tiered approach as forming “the meat and potatoes of differentiated instruction” (Tomlinson, 2009, as cited in Adams & Pierce, 2003, p. 31). Like most differentiated instructional methods, this tiered approach reaches all students within a classroom not just those with LDs. Both elementary and secondary school teachers can use a multi-tiered lesson to teach concepts and skills. Similarly, assessments can be tiered in both panels as well. While there are many examples of this tiered approach to be found in the literature and in usage by thoughtful teachers, there are few rigorous studies.Adams, C. M., & Pierce, R. L. (2003). Teaching by tiering. Science and Children, 41(3), 30–34.A step-by-step guide to creating a tiered lesson, using science as an example curriculum. Available through the National Science Teacher Association website. Click here to access the website.Servillo, K. R. (2009). You get to choose! Motivating students to read through differentiated instruction. TEACHING Exceptional Children Plus 5(5), 1–11.Like Adams and Pierce above, this is a step-by-step process to creating a tiered assessment, using reading as a curricular backbone.Tomlinson, C. (1999). The differentiated classroom: Responding to the needs of all learners. Alexandria, VA: Association for Supervision and Curriculum Development.This textbook provides great, easy to read instructions on differentiating in your classroom, with a strong focus on tiering both lessons and assignments.Adams, C. M., & Pierce, R. L. (2003). Teaching by tiering. Science and Children, 41(3), 30–34.Agran, M., Brown, F., Huges, C., Quirk, C, & Ryndak, D. (2014). Equity and full participation for individuals with severe learning disabilities: A vision for the future. Baltimore, MD: Paul H. Brooks Publishing Co.Barnes, M. A., & Wade-Woolley, L. (2007). Where there’s a will there are ways to close the achievement gap for children with learning difficulties. Orbit, 37, 9–13.Canada. Ontario Ministry of Education. (2005). Education for All: The report of the expert panel on literacy and numeracy instruction for students with special education needs, Kindergarten to Grade 6. Toronto, Ontario: Queen’s Printer for Ontario.Canada. Ontario Ministry of Education. (2008). Growing Success: Assessment, evaluation, and reporting in Ontario schools. Toronto, ON: Queen’s Printer for Ontario.Canada. Ontario Ministry of Education. (2011). Learning for all: A guide to effective assessment and instruction for all students, Kindergarten to Grade 12. (Draft). Toronto, ON: Queen’s Printer for Ontario.Cook, B. G., & Tankersley, M. (2013). Research based practices in special education. Boston, MA: Pearson.Floyd, K. K., & Judge, S. L. (2012). The efficacy of assistive technology on reading comprehension for post-secondary students with learning disabilities. Assistive Technology Outcomes and Benefits, 8, 48–64.Fuchs, D., & Deshler, D. D. (2007). What we need to know about responsiveness to intervention (and shouldn’t be afraid to ask). Learning Disabilities Research & Practice, 22, 129–136.Fuchs, L.S., Compton, D.L., Fuchs, D., Paulsen, K., Bryant, J. & Hamlett, C.L. (2005). Responsiveness to intervention: Preventing and identifying mathematics disability. Teaching Exceptional Children, 37(4), 60-63.Fuchs, L.S., Fuchs, D., & Prentice, K. (2004). Responsiveness to mathematical problem-solving instruction among students with risk for mathematics disability with and without risk for reading disability. Journal of Learning Disabilities, 4, 293-306.Hasselbring, T. S., & Bausch, M. E. (2005). Assistive technologies for reading: text reader programs, word-prediciton software, and other aids empower youth with learning disabilities. Educational Leadership, 63(4), 72–75.Hutchinson, N. (2013). Inclusion of exceptional learning in Canadian schools: A practical handbook for teachers (4th ed.). Toronto, ON: Pearson.Katz, J. (2012). Teaching to diversity: The three-block model of universal design for learning. Winnipeg, MB: Portage & Main Press.Mastroppieri, M. A., Scruggs, T. E., Hauth, C., & Allen-Bronaugh, D. (2012). Instructional interventions for students with mathematics learning disabilities. In B. Wong & D. L. Butler (Eds.), Learning About Learning Disabilities (4th ed.) (pp. 217–242). London, United Kingdom: Academic Press.Mattatall, C. (2008, June). Gauging the readiness of Canadian school districts to implement responsiveness to intervention. Paper presented at the annual meeting of the Canadian Society for the Study of Education, Vancouver, B. C.National Reading Panel. Teaching children to read: An evidence-based assessment of the scientific research literature on reading and its implications for reading instruction. Washington, DC:National Institute of Child Health and Human Development.Servillo, K. R. (2009). You get to choose! Motivating students to read through differentiated instruction. TEACHING Exceptional Children Plus 5(5), 1–11.Shapiro, E. S. (2014). Tiered instruction and intervention in a response-to-intervention-model. Retrieved from: http://www.rtinetwork.org/essential/tieredinstruction/tiered-instruction-and-intervention-rti-modelVaugh, S., Linan-Thompson, S., Kouzekanani, K., Bryan, D. P., Sickson, S., & Blozis, S. A. (2003c). Reading instruction grouping for students with reading difficulties. Remedial and Special Education 24, 301–315.Vaughn, S. & Fuchs, L. S. (2003a). Redefining learning disabilities as inadequate response to instruction: The promise and potential problems. Learning Disabilities Research & Practice, 18, 137 – 146.Vaughn, S., Linan-Thompson, S., & Hickman, P. (2003b). Response to instruction as a means of identifying students with reading/learning disabilities. Exceptional Children, 69, 391–409.Kyle Robinson is entering his second year in the Master of Education program at Queen’s University, with a focus on the Inclusion of Exceptional Students. Kyle is an OCT certified teacher (I/S), and has taught in schools in the Limestone and Toronto District School Boards. Besides inclusion, Kyle’s research interests also include the Psychology of Learning Disabilities, Special Education programs in Secondary Schools, and the History and Philosophy of Education.Nancy L. Hutchinson is a professor of Cognitive Studies in the Faculty of Education at Queen’s University. Her research has focused on teaching students with learning disabilities (e.g., math and career development) and on enhancing workplace learning and co-operative education for students with disabilities and those at risk of dropping out of school. In the past five years, in addition to her research on transition out of school, Nancy has worked with a collaborative research group involving researchers from Ontario, Quebec, and Nova Scotia on transition into school of children with severe disabilities. She teaches courses on inclusive education in the preservice teacher education program as well as doctoral seminars on social cognition and master’s courses on topics including learning disabilities, inclusion, and qualitative research. She has published six editions of a textbook on teaching students with disabilities in the regular classroom and two editions of a companion casebook. 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