A Comparative Analysis of Access to Education for Students with

A Comparative Analysis of Access to Education for

Students with Disabilities in Brazil, Canada, and South

Africa

Elisheba Kiru

and North Cooc

University of Texas at Austin

Abstract

Access to education for children with disabilities remains a signiﬁcant challenge in many countries

despite international agreement of its importance. This paper describes results from a comparative

analysis of education for students with disabilities in Brazil, Canada, and South Africa with a focus on

how differences in disability policies, pedagogy, professional development for teachers, and

sociocultural factors shape access to schooling in these three countries. The paper also reviews

relevant literature to discuss how structural and cultural barriers can exacerbate exclusionary

practices. The analysis highlights ways that these countries and others can increase participation in

society and enhance quality of life for individuals with disabilities.

Key Words: Access to Education, Disability, Brazil, Canada, South Africa

The Salamanca Statement declares that every child has a

basic right to education and re cognizes their unique

characteristics, interests, abilities, an d learning needs

(UNESCO, 1994). This declaration challenges governments

to i nvest in early intervention s trategies and develop

inclusive education principles in legislation and in policy

implementation. In a similar vein, the Convention on the

Rights of Persons with Disabilities (CRPD)(UN, 2006) is

presented as a non-discriminatory agreement among

signatories to provide transformative changes in inclusive

education and improve educational practices for individu-

als with disabilities (Winzer & Mazurek, 2014). In Article

26 of the Universal Declaration of Human Rights (UN,

1948), the United Nations emphasizes that all individuals

have the right to education. Despite these international

agreements over the last 60 years, access to education for

students with disabilities across the world continues to be

an area fraught with challenges and little progress.

As countri es continue to grapple with the realities of

inclusive education, challenges may vary across the

different education levels (e.g., students, classrooms,

schools), teaching areas (e.g., curriculum, pedagogy), and

for de mo gr ap hic groups ( e.g ., ethnic mi no ri tie s versus

majority and female versus male). A multidimensional

comparative analysis framework is needed for a compre-

hensive examination of p ossible micro and macro factors

that are inherently complex in education systems (see

Bray & Thomas, 1995). This framework can lead to the

development of heuristics situated in local contexts that

are organically developed to answer questions that

directly impact students with disabilities in speciﬁc

settings. These ques tions include how to improve access

to schools, what type of disability legislation is effective,

which funding formulas are optimal, and how to improve

accountability.

In light of these tensions and challenges around

improving education for all, this paper examines access to

education for students with disabilities in Brazil, Canada,

and South Africa. This comparative analysis focuses on (a)

disability legislation and policies, (b) pedagogy, (c) access

to services and resources, (d) professional dev elopment for

teachers, (e) perceptions on disability, and (f ) sociocult ural

challenges. In addition, this comparative analysis identiﬁes

initiatives and strategies that exist in the three countries to

Vol. 21, No. 2 pp. 34–44

increase access to education for students with disabilities.

Such initiatives can beneﬁt policy makers and various

stakeholders (e.g., school leaders) tasked with the imple-

mentation and attainment of Education for All (EFA)

(UNESCO, 2000) or the Millennium De velopment Goals

(Millennium Project, 2006). To summarize, this compar-

ative analysis seeks to answer the following questions:

1. What is the current status of access to education for

students with disabilities in Brazil, Canada, and South

Africa?

2. What barriers impact the real izati on of access to

education for students with disabilities in these three

countries?

Lastly, the paper discusses possible transferrable lessons

regarding access to education for students with disabilities

from the three countries.

Rationale for Comparing Brazil, Canada, and

South Africa

On the surface, Brazil, Canada, and South Africa may

seem to have little in common in terms of education

systems. However, the three countries share similarities

that can provide insight into existing challenges and

potential solutions in improving access to education for

students with disabilities. At the same time, due to clear

contextual and cultural differences, there are caveats when

making any comparisons. One shared attribute among the

countries is their involvement in international agreements

to provide education for all students. To this end, the three

countries are signatories of the CRPD in 2008, 2010, and

2007, respectively. Second, Canada is a member of the

Organizatio n for Ec onom i c Coo per ati on Dev elo p men t

(OECD), while Brazil and South Africa are term ed as

non-member countries (OECD, 2017). The criteria for

membership in the OECD include: an open economy, a

pluralist democracy, and respect for human rights.

Although the criteria for participating in the OECD are

not without controversy, the direct participation by Canada

and indirect participation in OECD projects by Brazil and

South Africa reﬂects the acknowledgement by international

bodies of these countries’ efforts to provide quality

education and long-term economic development. Third,

while there are cultural and linguistic differences across the

three countries, there is signiﬁcant diversity within each

country that provides an opportunity to examine how

marginalized groups in different contexts interact with

exclusionary policies and practices. Fourth, Brazil, Canada

and South Africa share decentralized education systems

that may impact decision-making and policy implementa-

tion in education. Lastly, the contrast in resources among

the three countr ies can provide insight into how govern-

ments provide quality spe cial education services for

children with disabilities.

DEMOGRAPHIC BACKGROUND

The three countries vary widely in terms of geography,

ethnic diversity, economi c development, and inequality.

Brazil is the world’s ﬁfth largest country geographically,

while Canada is second and South Africa ranks 25

(World

Bank, 2016). Economically, Brazil is currently faced with

some instability and high inﬂation rates, but experienced

economic growth from 2003-2013, as shown in Table 1.

The country also has a high level of income inequality as

indicated by the Gini coefﬁcient. In contrast, Canada has

one of the largest economies and has experienced solid

economic growth and low levels of income inequality.

South Africa is an upper middle-income country and has a

Gini coefﬁcient showing high inequalities in the country.

A BRIEF HISTORY OF SPECIAL EDUCATI ON IN

BRAZIL, CANADA, AND SOUTH AFRICA

Special education in Brazil has evolved since 1600 when the

ﬁrst school for the individuals with physical impairment

was established. This was followed with the establishment

of the ﬁrst school for children who are blind in Rio de

Janeiro in 1854 and the ﬁrst institution for the deaf in 1856

(Lin, 1987). More than a centur y later, a rethinking of the

special education ﬁeld emerged in the 1980s following a

call to democratize the teaching and learning process (Glat

& Ferreira, n.d). In the late 1950s and early 1960s, special

education services were provided in institution s. These

were followed with the establishment of special schools,

which preserved the status quo because the schools were

not required to undergo any profound modiﬁcations (Lin,

1987). In 1989, Brazil implemented an inclusion policy in

its new constitution that changed the nature of services for

students with disabilities and emphasized their social

integration into schools (Santos, 2001).

In contrast, special education in Canada started in mid-

1800s with specialized schools for individuals with visual

impairments (Dworet & Bennett 2002). Currently, educa-

tional decisions are under provincial jurisdiction, which

means a student’s right to educational services is acknowl-

edged by a province, as opposed to explicit guarantee in

Canadian legislation (Shah, 2010; Towle, 2015). The

Charter of Rights and Freedoms mandates the provision

of equal treatment under the law without discrimination

based on disability (Disabi lity Righ ts Educat ion and

Defense Fund, 1982). In particular, much attention has

focused on the education of First Nations students. First

Nations are the original inhabitants of Canada, often

referred to as India ns (Government of Canada, 2014). Prior

to 1980, First Nations students with special needs attending

First Nations schools were not afforded any funding by the

federal government. They also received the least amount of

money from the Indian and Northern Affairs of Canada,

which left families with little choice but to move to private

schools or the provincial schools away from the reserves

Journal of International Special Needs Education

(Philips, 2010). The increased awareness of a need for a

comprehensive special education pr ogram throughout

Canada for First Nations students with special needs gained

momentum in the 1990s (Philips, 2010). Despite these

efforts, First Nations students do not have the luxury of a

federal education law that mandates the provision of special

education services and must depend on the provincial laws

and policies. The governme nt’s responsibility in providing

access to First Nations special education students in reserve

or off-reserve schools is critical and underscores Philips’

(2010) call for the explicitness of laws that acknowledge the

First Nations students with special needs.

In South Africa, Muthukrishna and Schoeman (2000)

note that, historically, education for a large population of

learners was marked with extreme neglect where existing

legislation and policy reiﬁed racial segregation and

inequality. Education and support services were provided

along racial lines, widening the inequalities between the

African learners and White and Indian learners. Students

with disabilities were offered a second system of education,

separated from peers without disabilities. With the

founding of a new government in 1994, initiatives were

implemented to combat these discriminatory practices.

Education policies focused on education as a basic human

right, quality of education for all, equity, curriculum access,

and rights of parents—all of which were included in The

Constitution of the Republic of South Africa Department of

Justice (1996). Currently, education for students with

special needs is provided in special schools, full-service

schools, and regular schools (Nel & Grosser, 2016).

It is important to emphasize that all thre e countries

share a past enmeshed in discriminatory practices. In South

Africa, the apartheid era came to an end in 1994 after a half

century of segregation between non-White and White

South Africans (Pather, 2011). In Brazil, policies were

characterized by income and class segregation where

children from low-income families and children with

disabilities were unable to access similar educational

opportunities as the wealthy. In Cana da, the movement

towards integration of students with disabilities into regular

schools came to the fore in 1985 (Porter, 2008). In addition

to a continued call for appropriate access to education for

students with disabilities, students with special education

needs enrolled in Canadian French immersion program

seldom had access to special education programs and

services available to their peers in regular English programs,

forcing these students to transfer to different schools (Wise,

2011). Similarly, First Nations students had access to

schools in the reserves but did not have access to special

education services available in the provincial school systems

(Philips, 2010).

Given the different historical developments in special

education policies in Brazil, Canada, and South Africa, the

countries provide an opportunity for a comparative analysis

of their progress in providing access to education for

students with disabilities. In South Africa, 70% of the

student population with disabilities is not enrolled in

school and the remaining percentage receives their

education in special schools, which can be considered

segregated settings (Donahue & Bornman, 2014). In Brazil,

Table 1

Demographic, Educational, Social and Economic Measures of Development on Brazil, Canada, and South Africa

Brazil Canada South Africa

Former colony Portugal Britain Britain

Area (sq. km) 8,515,767 9,984,670 1,221,037

Population (2016) 207,652,865 35,151,728 55,908,900

Ethnic groups 47.73% White

43.13% Mult iracial

7.61% Black

1.09 % Asian

0.43% Amerindian

76.7% White

14.2 % Asian

4.3% Aboriginal

2.9% Black

1.2% Latin America

0.5% Multiracial

0.3% Other

80.2% Black

8.8% Colored

8.4% White

2.5% Asian

Ofﬁcial languages Portuguese English and French 11 languages

Gini coefﬁcient 51.48 33.68 63.38

Children with disabilities (5-14) 468,601 173,180 609,671

Percent of students with disabilities in school 0.71% 40% 7.6%

Locus of decision making Decentralized Decentralized Decentralized

Note. Sources: Brazilian Institute of Geography and Statistics (2010; 2016); Statistics Canada (2013; 2016); Statistics

South Africa (2016); World Bank (2016); World Health Organization (2011 ).

Journal of International Special Needs Education

census reports show 448,601 pupils (0.8% of the total of

more than 50 million pupils) with special needs were

enrolled in the basic education (i.e., mainstream) system in

2002 (World Health Organization, 2011). In Canada, 40%

of students with disabilities have access to education, the

highest of the three countries (see Table 1).

CURRENT CHALLENGES

In seekin g to answer the research questions and provide a

comparative analysis of access to education for children

with disabilities, the paper will focus on current challenges

in the following areas: disability legislation and policies,

pedagogy, teacher professional development, access to

resources and services, and sociocultural challenges.

Disability Legislation and Policies

South Africa is a signatory of the CRPD and is required

to adhere to the mandates of the treaty that includes the

protection of the rights of persons with disabilities through

provision of equal access to education. Speciﬁcally, Article

24 mandates signatory countries to ensure opportunities

for appropriate and inclusive education. The apartheid era

(1948-1991) in South Africa was characterized by years of

segregated education practices and lack of provision of

special education services to students, particularly Blacks.

In 1994, following the democratization of South Africa, the

Department of Education made attempts to overhaul

educational policies in an effort to combat discriminatory

practices (Donohue & Bornman, 2014). In addition to

eliminating segregated education, the White Paper 6 policy

document on inclusive education in South Africa outlined

that the provision of educational services for children with

disabilities may occur in (a) mainstream schools for

moderately disabled lea rners, (b) full-service schools which

are adapted mainstream schools, and (c) special schools

which are exclusive for learners with severe disabilities

(Department of Education, 2001). The White Paper 6 seeks

to yield long-term economic beneﬁts for the society as

students with disabilities become economically and socially

empowered through an inclusive education (Murungi,

2015).

South Africa’s enactment of policies for inclusive

education is a signiﬁcant step towards providing equitable

access to education to students with disabilities. However,

the implementation of these policies has faced challenges

that have diminished their impact. According to Donohue

and Bornman (2014), there is a lack of consensus on the

deﬁnition of disability, making it difﬁcult for stakeholders

to articulate effective action. This ambiguity in discourse

may lead to a lack of commitment in the provision of

services. The lack of clarity with policy mandates leaves

room for inefﬁciency, ambivalence, and accountability

challenges.

Similar to South Africa, Brazil has put laws in place

that focus on the provision of education services to

students with disabilities. For instance, Public Law 1989

provided legal support and the National Policy of Special

Education launched in 1994 promoted the protection and

inclusion of students with disabilities in society (Santos,

2001). Mirroring the compliance concerns in South Africa,

accountability to these disability laws and mandates is

lacking in Brazil, which slows down the progress of

inclusion and access to education for students with

disabilities. Addition ally, discrepancies abound reg arding

the law and the reality in the classroom. For instance,

Chakraborti-Ghosh, Orellana, and Jones (2014) reported

one teacher’s remarks that the law states only three

students with disabilities should be in a general education

classroom, but usually there are more than three students.

This contradiction is indicative of the confusion surround-

ing concepts and deﬁnitions that curtail needed commit-

ment to inclusive education (Chakraborti-Ghosh, Orellana,

& Jones, 2014; Santos, 2001). In additio n, parental

involvement in the education or decision making for

students with disabilities is not legally mandated (Chakra-

borti-Ghosh et al., 2014). This lack of participation from

families places the schools in a position to make sole

decisions that impact a student’s schooling life cycle and

beyond.

Canadian provinces and territories develop their own

education policies; therefore, exceptionality and special

education may have different meanings across the provinces

and territories, and so do the special education services

(Oloo, 2006). Historically, students with disabilities were

institutionalized and received special education services in

segregated settings (Towle, 2015). In 1980, Bill 82 passed

into law requiring s chool boards to develop special

education services for students with special needs (Mor-

gan, 2003). Towle (2015) notes that as recently as 2012,

the Supreme Court of Canada, which has jurisdiction over

each province and territory, required school programs to

meet the needs for individual students based on appropri-

ate assessment and programs. Mor eover, Towle notes that

access to special education services is offered in the general

education classroom, in separate classrooms, or in pull out

sessions. Depending on the province or territory, special

education services and policies have different translations,

including: most appropriate placement (Alberta ), most

enabling environment (Prince Edward Island) or regular

classroom ﬁrst (Ontario; Dworett & Bennett, 2002). These

varied labels illustrate potential differences in the inter-

pretations of terms that may negatively impact and reduce

access to the provision of services for students with

disabilities.

In both the Brazilian and South African contexts, the

available policies on inclusion of students with disabilities

provide inadequa te framework s for the prov ision of

services to students with disabilit ies (Donohue & Born-

Journal of International Special Needs Education

man, 2014; Murungi, 2015). For South Africa, the White

Paper 6 is not clear on whether the students must receive

an education solely in mainstream settings or if the parents

and students have a choice on the provision of part or total

services in special schools depending on the needs of the

students (Murungi, 2015). Similarly, in South Africa,

policies on inclusion are ambiguous on the provision of

services for students with disa bilities. This lack of clarity is

one of the reasons why students with disabilities mainly

receive their education in special schools, as highlighted in

Donohue and Bornman (2014).

Pedagogy

Pedagogy inclu des strategies that teachers incorporate

in their teaching and learning contexts, albeit without

always elaborating the historical, cultural or personal

factors that shape these practices (Loveless, DeVoogd, &

Bohlin, 2001). The Salamanca Statement (UNESCO , 1994)

acknowledges that each student has unique characteristics,

abilities, and interests. What does this mean for teachers of

students with special needs? How does this afﬁrmation

inﬂuence pedagogy? Understanding pedagogies that inform

teachers’ epistemologies and learning theories is critical in

furthering their reproduction or restructuring them to

allow for transformative teachin g and learning experiences.

Educators in contexts where students have historically

experienced practices that reiﬁed inaccurate stereotypes,

devalued social and cultural capital, and perpetuated lack

of access to educational opportunities can beneﬁt from

professional development geared towards developing and

nurturing emancipatory pedagogy.

An example of a pedagogical overhaul is exempliﬁed in

South Africa. Curriculum in South Africa has two

approaches, policy and knowledge. Curriculum-as-policy

is marked by struggles of the opposing groups represented

in the curriculum, whereas curriculum as knowledge

revolves ar ound knowledge con stru ction (Chisholm,

2005). These two approaches were exempliﬁed in the

development of South Africa’s revised national curriculum,

Curriculum 2005 (Department of Education, 2002b), a

product of social contests among multiple stakeholders.

Environmentalists, historians, lobbyists, bureaucrats, and

religious activists were involved in the revision. The

revision of the curriculum inv olved a rethin king of

knowledge construction with the uncovering of the role

of the school and the place of the student in teaching and

learning. This revision ushered in a pedago gical shift away

from education in the apartheid era that was more teacher-

centered and overlooked students’ cultural knowledge

(Chisholm, 2005). Curriculum 2005 also introduced

notions of social justice and human rights, which are

critical values towards a democratic society. Muthukrishna

and Schoeman (2000) observe that although Curriculum

2005 was controversial in its development as a national

curriculum with a transformational outcome -based educa-

tion approach, it is learner-centered, driven by multidi-

mensional assessments that monitor gains from previous

performance—a new approach in the post-apartheid era.

It is important to note that teachers develop pedagog-

ical practices over time (Bourdieu, 1977). Hence, it is fair

to argue that in a context with a historical past where

discriminatory and oppressive practices existed in the

education system, teachers will beneﬁt from a change of

pedagogy that fosters equitable learning experiences for all

students. Donohue and Bornman’s (2014) argument that

teachers need revised cultures of practice can serve an

important role in making inclusive policies a reality. White

Paper 6, the South African inclu sive policy document,

embraces the notion that reforming teaching practices,

behavior, and curriculum is vital in meeting the learning

needs of all learners (Maher, 2009).

In Brazil, in contrast, there is dearth of literature that

focuses on pedagogy for students with disabilities in

inclusive education settings. Inadequate teacher training

undermines access to quality education for students with

disabilities. In addition, teachers in Brazil have noted that

students identiﬁed with mild/mod erate disabilities are

more likely to access the general education curriculum in

a regular classroom compared to students identiﬁed with

severe disabilities (Chakraborti-Ghosh et al., 2014).

Professional Development

Bourdieu (1977) explains that people have disposi-

tions developed over time as a result of a person’s

background, family, environment, and beliefs that form

an individual’s unique habitus. Belland (2009) posits that

teachers also possess habitus that impact their teachin g

beliefs and practices. With rapid developments in policy

and legislati on, teacher professional development plays a

signiﬁcant role in empowering teachers with skills that can

increase their conﬁdence in deploying relevant pedagogies

and ameliorating teaching practices that reify discrimina-

tory beliefs. High quality professional development can

alleviate possible frustrations experienced by teachers that

may arise due to feelings of inadequacy with the tasks at

hand.

Professional development for teachers continues to be

a challenge in Brazil, Canada, and South Africa. Chakra-

borti-Ghosh et al. (2014) notes that teachers in Brazil feel

ill-equipped and less conﬁdent about teaching students

with disabilities. Although the Brazilian governmen t has

passed federal laws on inclusion services for students with

disabilities, the ﬁnancial investment in teacher training has

been minimal. Similarly, in South Africa, low job

satisfaction rates among teachers who teach in special

schools is a challenge and inadequate funding curtails

progress for an inclusive education (Strydom, Nortje

Beukes, Esterhuyse, & Der Westhuizen, 2012). In Canada,

all teachers must be certiﬁed and, depending on the

Journal of International Special Needs Education

province or territory, teachers may need to complete

further training to teach special education classes. Dworet

and Bennett (2002) highlight the need for continued

teacher training in meeting the needs of ethnically diverse

students in Canada, particularly First Nations students and

students who speak English as a second language.

Inadequate teacher training is also a challenge in South

Africa. In Greyling’s (2009) study of teachers, many

expressed a lack of conﬁdence in meeting the needs of

students with disabilities. The teachers pref erred focused

training in this area instead of general curriculum training.

In addition to this preparation gap, Pather (2011) argues

that since specialist services such as occupational therapists

and remedial educators are in short supply, the interna-

tional model of providing special education services to

students with disabilities may not ﬁt with the infrastructure

available in South Africa. This lack of contextual ﬁt

highlights the need to structure the education model

depending on available resources in the speciﬁc contexts.

Access to Services and Resources

Unequal wealth distributions and economic situations

in South Africa and Brazil fuel poverty conditions that

impact students’ access to educational services. Students in

rural areas are mostly affected by the lack of proper

infrastructure, such as inaccessibility to public transport

and subsequently access to schools (Glat & Ferreira, n.d).

Teachers in rural areas in South Africa are faced with

unreliable ele ctricity, limited school supplies, and a

shortage of specialists, including psychologists, occupa-

tional therapists, and speech therapists (Pather, 2011).

Another compounding factor that limits access to special

education services in South Africa is entrance fees in the

special schools, especially at the high school level. On a

positive note, Pather’s (2011) qualitative study in a Black

rural secondary school documented positive strides in

providing access to education for students with special

needs. These improvements have been made through peer

and community support; for instance, a stude nt withou t

disabilities may offer to push a peer’s wheelchair, or

unemployed local artisans volunteer to complete a ramp.

Although the sustainability of this approach is unclear,

these collaborative efforts demonstrate ways in which

schools and communities can improve access for students

with disabilities.

In Brazil there has been less investment in education

that has impacted the quality of school services for general

education students and particularly for students with

special needs (Watson, 2013). Brazil has a parallel

education system, one for students with special education

needs and another for students without special education

needs. In this segregated system, students with special

education needs are marginalized and isolated from peers,

reinforcing negative perceptions of this student population.

Additionally, students with special needs from low-income

families are further marginalized by the lack of access to

services.

Canada’s investment in education is second after

health care spending (World Bank, 2016). In 1997,

Canada passed Bill 160 that put in place an educ ation

funding formula that restructured how monies were

generated. Instead of local taxes, a provincial pooling of

funds was proposed (Morgan, 2003). The budget cuts were

followed by a recommitment to invest in education, and

speciﬁcally special education. This call for action from

various stakeholders demonstrates the effort required to

ensure that students with disabilities remain at the center

of resource allocation and funding. However, access to

education may be compromised for students at the local

level. In Prince Edward Island (PEI), a rural province with

high unemployment rate and limited resources, success in

providing special education services to students in their

neighborhood schools has been attributed to community

partnerships w ith schools (Timmons, 2006). These

resources have fostered teacher-training, the development

of programs for students with autism, and increased

satisfaction from parents regarding services provided to

their children. However, students may experience lengthy

wait times before receiving diagnostic assessments, which

delays special educat ion services (Towle, 2015). Larger

class sizes also make it difﬁcult for teachers to meet the

learning needs of all of the students in the classroom.

In South Africa, the Department of Basic Education

(2011) rep orted that nearly 500,000 children with

disabilities of school age a re not attending school.

According to the 2013 General Household Survey, of the

children with disabilities who do not attend school, 67%

report severe disabilities and would therefore require

placement in special schools (Do nohue & Bornman,

2014). Muthukrishna and Schoeman (2000) ﬁnd that

language limitations may hinder learning in South Africa.

Students with disabilities who do not receive instruction in

their ﬁrst language are further marginalized and unable to

access the curriculum.

Sociocultural Challenges

Bronfenbrenner’s (1979) ecological framework makes

the argument that learning at the micro level exists in larger

historical, political, cultural, social, and economic contexts.

The deﬁnitions of disability are often socially constructed

and play out within these contexts. Subsequently, how

disability is understood in society depends on the social

contexts.

In Brazil, Watson (2013) describes how disability is

associated with poverty and a deviance from the normal

social order. The focus on deviance places disabil ities and

special education services in the hands o f medical

personnel instead of educators. Individuals who are able

to contribute the most to the society are the most valued

Journal of International Special Needs Education

and individuals with disabilities are relegated to inferior

experiences (Watson, 2013). Similarly, in South Africa,

negative at titudes and the reje ction of students with

disabilities from peers, the public, and schools contribute

to parental resignations that keep children from accessing

an education (Maher, 2009; Yssel, Engelbrecht, Oswald,

Eloff, & Swart, 2007). Parents further perceive educating a

student with a disability as expensive with little returns on

the investment (Donohue & Bornman, 2014). Muthuk-

rishna and Schoeman (2000) also highlight the existing

deﬁcit views of students with disabilities in South Africa

whereby psychometric tests are routinely used for

placement purposes without consideration of prior educa-

tional opportunities. This practice is against the South

African Schools Act, yet it is inappropriately used for

diagnostic purp oses.

In Can ada, individuals with disabilities are also

stigmatized in society, alienated from peers, and face

negative stereotypes. This is especially the case for students

who attend special schools where there is little contact with

peers without disabilities (Bunch & Valeo, 2004). Media

representation plays a signiﬁcant role in social perceptions

of individuals with disabiliti es. Devotta, Wilton, and

Yiannakoulias (2013) examine d tren ds in media represen-

tations of disabilities in Canada over a ten-year period and

reported encouraging changes. For instance, individuals

with disabilities were represented as having an identity

besides having a di sability. The authors also highlighted a

shift in terminology and language used for individuals with

disabilities. In 1998, most reporting used language that

focused on limitations (e.g., handicapped) but in 2008 the

language used was more accepting of disabilities (e.g.,

person-ﬁrst language). In addition, the content in 2008

addressed topics such as disability awareness, barriers, and

social inclusion that emphasized supports for in dividuals

with disabilities.

DISCUSSION

The purpose of this paper was to examine access to

education for children with disabilities in Brazil, Canada,

and South Africa. This comparative analysis provides

insights into the current challeng es within each country.

These include a range of cultural and structural issues that

currently exacerbate educational equity for children with

disabilities. We discuss potent ial policy implications and

areas of priority moving forward.

Access to Education for Students with Disabilities

The data provided in this analysis show that large

percentages of students with disabilities in Brazil and South

Africa are not receiving basic education or special

education services. This continues despite the legal

frameworks in place stipulating education as a basic right

for all individuals or the coun tries’ part icipation i n

international agreements that support education for all

students. In comparison to Brazil and South Africa, Canada

has the highest percentage of students with disabilities

having access to special education services. This variability

may be a result of different levels of ﬁnancial resources

among t he three countries, as well as the diff erent

jurisdictions in charge of educational policies implemen-

tation. In Brazil and South Africa the government has a

larger mandate to implement the education policies but

appear less efﬁcient, whereas in Cana da the provinces and

territories are responsible for designing and implementing

education policies.

It is important to situate these ﬁndings in historical

and cultural contexts to discern whether countries have

made any progress, and to understand the inﬂuence of

such contexts in their current challenges of access to

education. This paper shows how Brazil and South Africa

share similar historic pasts of segregation and discrimina-

tory practices in providing students with disabilities access

to education in an equitable and systematic manner.

Similarly, certain groups in Canada have experienced

marginalization and limited access to special education

services, including First Nations students and French-

speaking students in Canadian English Immersion schools

who are forced to move to English-only schools to receive

special education services. Although educational opportu-

nities are available, the provision of special education is a

continued struggle for certain student groups in these

countries.

International agreements on access to education at the

global level funnel through the stru ctures of a country’s

education system. On the Bray and Thomas (1995) cube,

comparativisits can examine different dimensions to

explore intersectionalities of various policy related factors

and gain a deeper understanding of the larger ecosystem.

For instance, at the international level the role of

agreements and treaties for students with disabilities

pertain to the protection of their rights and commitments

from governments to provide access to services. As seen in

this paper, the implementation of these agreement s at the

country, school, or individual level is impacted by a myriad

of complex variables that intersect and inﬂuence policy

development, resource allocation, and eventually access to

education.

Barriers to Education for Students with Disabilities

In Canada, special education services are provided in

different settings depending on the policies in speciﬁc

provinces and territories, meaning that a student with a

disability may qualify for special education service in one

province and fail to qualify for similar services in a different

setting. This observation is present in Brazil and South

Africa as well, a possible result of the varying deﬁnitions of

the term disability. The distribution of resources determines

the special education services available for students with

disabilities and consequently access to education. For

Journal of International Special Needs Education

instance, in Canada, funding allocation is dependent on

the need, degree, and severity of the disability (Dworet &

Bennett 2002). This is not the case for Brazil and South

Africa. Though arguably certain disabilities may require

more resources, funding allocation should be more ﬂexible

to allow for the provision of necessary services. In addition,

the locus of control and decision-making directly impacts

implementation of education policies. In Canada, the

decision on the right to education is left to the jurisdiction

of the provinces, which seems to empower the provinces

with a powerful mandate to an individual’s right to

education. Brazil and South Afr ica provide a constitutional

protection to all students to receive an education.

Additional barriers include ambiguity in disability legisla-

tion and policies, traditional pedagogical views on

disability based on deﬁcit views, negative sociocultural

attitudes, inadequate teacher professional development,

and unequal and limited access to resources and services. It

is clear that education policies, such as allocation of

resources and the criterion for identiﬁcation of special

education needs, have a direct impact on the access to

education for students with disabilities. The role of the

government determines how the decis ions are implement-

ed and which priorities are addressed to ensure students

with disabilities have access to special education services.

Effective Policies

The three countries have implemented strategies and

initiatives to allevia te some of the existing barriers that limit

access to education for students with special needs. One of

these initiatives has been reali zed through changes in

curriculum and pedagogy. Pedagogy provides an important

vehicle through which students access the curriculum.

Curriculum 2005 (Department of Education, 2002b), a

national curriculum based on transformation-based out-

comes in South Africa, represents an intentional and

radical approach towards the delivery of a revolutionary

schooling experience in South Africa. The curriculum was

developed in collaboration with various stakeholders with

an eye towards the facilitation of social justice and equity.

This can be argued as especially true for individuals who

have been historically marginalized, including students

with disabilities. An intentional focus on a national

transformative curriculum can provide a critical space to

inﬂuence teacher mindsets, inform cultures of practice, and

systematically create transformative educational practices.

Although South Africa continues to struggle to reap the

beneﬁts of Curriculum 2005 (Department of Education,

2002b), especially in providing the teachers with the

necessary support (Pillay, Smit, & Loock, 2013), there is

documented evidence of initiatives towards overhauling

pedagogical practices that promote equitable instruction

(Maher, 2009). Also curricula changes are paramount in

developing inclusionary practices and access to education

for all students.

Community involvement is one approach that can pull

together available resources and lead to small and steady

progress towards increasing access to education for all

students. For instance, in South Africa, parental advocacy

is critical in the implementation of inclusive practices for

students with disabilities. This grassroots movement can be

a source of potential mobilization of people and ideas that

lead to improvements in the quality of education services

for students with disabilities. This grassroots movement is

also documented in Brazil where advocacy groups have

emerged and channe led much needed attention towards

initiatives with an emancipatory lens on disability (Connor,

Block, Calder, Rembis, & Watson, 2014). The approach

taken by the advocacy groups in Brazil is transferrable to

the South African context because of the groups’ emphasis

on reducing stigma of individuals with disabilities. Also,

the advocacy groups work in conjunction with scholars,

policy developers, and special education service providers

to challenge traditional views of disability as deﬁciency,

and empower individuals with disabilities through

changed discourses and discursive practices.

In South Africa, like Canada and Brazil, there are

varied understandings of the term disability, and inclusion,

resulting in i naction and complacency in providing

students with disabilities access to resources and services.

Ultimately, this ambiguity denies students an optimal

educational experience, as parents remain unaware of their

rights and become less active in advocating for their

children’s rights. The Disabled Children’s Action group in

South Africa, formed in 1993, deserv es to be mentioned as

a local organization involving parents and the communi-

ties. The group takes the initiative to increase access to

education by providing educational opportunities that tap

into the potential for students with disabilities (DICAG,

2001). Ultimately, the lack of clarity of these terms

impedes access to educational services, while the dominant

sociocultural attitudes in the three countries reveal a need

to destigmatize beliefs and attitudes towards individuals

with disabilities.

These changes can arise from more sensitive termi-

nology used in policy documents and in media presenta-

tions and broader discourses about disabilities. For

instance, the International Classiﬁcation of Functioning,

Disability and Health (ICF) shift in conceptualizing

disability on a continuum is a laudable move towards

weakening the value-laden deﬁn itio n of disability as

previously explained through non-environmental factors.

This deﬁnition acknowledges the interplay between

environmental and personal factors in the deﬁnition of

disability (WHO, 2011). The ICF continuum allows

practitioners, service providers, parents and policy makers

to develop a richer, explicit understanding of the term

disability. ICF outlines disabilities as categorized in three

areas; (a) impairments related to body functions, (b)

activity limitations due to difﬁculties engaging in activities,

Journal of International Special Needs Education

and (c) participation in terms of social integration in

employment or transportation access. Whether this change

in meaning will result in signiﬁcant change remains to be

seen; however, it is a step towards an inclusive society by

unpacking and better understanding disability.

CONCLUSION

In summary, numerous barriers exist that limit the access to

education for students with disabilities in Brazil, Canada,

and South Africa. This paper highlights possible ways that

the barriers can be tackled to ensure access to education.

Progress can be achieve d through curricula and pedagogical

changes, teacher training, increased funding, equitable

distribution of resources, gras sroots moveme nts, and

empowering messages about people with disabilities. There

is a need for more critical analysis from researchers and

stakeholders on the implementation of international treaties

and global policies in local contexts through a closer

examination of individual countries, their resources,

strengths, and needs (Yang, 2014). While acknowledging

the great strides and pos itive trends that Brazil, Canada, and

South African have taken towards providing access to

students with disabilities through inclusive education, we

concur with Ho ugaard (2007) that ‘‘ the process of

inclusion requires great courage in a world that has not

yet learned to value difference ’’ (p. 4). Similarly, Muthuk-

rishna and Schoeman’s (2000) make a progressive call to

policy makers, stakeholders, and school districts to depart

from a focus on special needs, to an encompassing notion of

barrie rs to learning and development for students with

disabilities. This perspective would hopefully be another

step towards dismantling the stereotypes associated with

labeling students with disabilities and inequitable provision

of instruction and services that deny many students with

disabilities access to education.

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CORRESPONDENCE

Corresponding author’s address: 1 University Station, Stop

5300, Austin, TX, 78712.

Email: [email protected]. Phone: (512) 471-5017.

Journal of International Special Needs Education