Crafting Coherence from Complex Policy Messages : Educators ’ Perceptions of Special Education and Standards-Based Accountability Policies

Federal special education and accountability policies requires that educators individualize instruction for students with disabilities, while simultaneously ensuring that the vast majority of these students meet age-based grade-level standards and assessment targets. In this paper, we examine this dynamic interplay between policies through analysis of policy documents and interviews that reveal how a sample of educators grapple with their simultaneous implementation. We found that educators made sense of some facets of the policies as complementary and others as contradictory. NCLB and IDEA offered consistent and specific guidelines defining “highly qualified” teachers and educators reported a clear and accurate understanding of these policy demands. On an issue where there was no specific guidance from NCLB–the placement of special education students–educators interpreted the law as promoting the inclusion of more students in general education courses, often to an extent that contradicted the guidance offered by IDEA. With respect to fundamental issues of teaching and learning, NCLB and IDEA represent contradictory theories of action and educators perceived conflict and expressed concerns about unintended consequences for students. Based on our empirical findings, we conclude with a set of theoretical propositions regarding how the alignment of epaa aape Education Policy Analysis Archives Vol. 21 No. 12 2 policy messages influences educators’ interpretation of policies, which in turn may have implications for how they enact policies.

policy messages influences educators' interpretation of policies, which in turn may have implications for how they enact policies.Keywords: Accountability; education policies; special education.

Introduction
The public K-12 education system in the United States became increasingly subject to federal oversight because of the escalating demands of federal special education and standards-based accountability policies.Two landmark federal legislative efforts-the Elementary and Secondary Education Act (ESEA) of 1965 and the Education for All Handicapped Children Act of 1975 (subsequently renamed the Individuals with Disabilities Education Act, IDEA)-represent bold mandates with far-reaching consequences for local educators' practice (ESEA, 20 U.S.C. § 6301 and IDEA, 20 U.S.C. § 1400).At face value, the two acts have several similarities: most notably, a civil rights-based commitment to ensuring the education of vulnerable populations of children and youth.Yet, successive waves of the reauthorization of ESEA culminating in an era of test-based accountability, made universal by the 2001 passage of No Child Left Behind (NCLB), has led to concerns regarding the feasibility of simultaneously complying with the policy demands of these two acts.Specifically, NCLB's provision that the vast majority of students with disabilities meet agebased grade level standards is in direct tension with IDEA's emphasis on individualized educational services for students with disabilities.
Despite NCLB's potential to influence special education policy and practice, there has been very little scholarship examining its interplay with IDEA.This lack of attention might be due to a significant disconnect between special education and general education policy analysis and research.As Ramanathan (2008) notes, "Reform movements in special and general education have often mimicked the 'parallel play' of young children, using identical means to achieve similar goals while rarely communicating" (p.280).
The purpose of this paper is threefold.First, we examine how NCLB and IDEA (as written) are coherent and mutually reinforcing, plus the ways that these mandates present potential incoherence.Second, we describe ways that some teachers, principals and superintendents made sense of the dual policy mandates and attempted to craft a coherent response.Finally, we offer a set of tentative propositions to guide study of the implementation of two or more converging policies with attention to both policies as written and as interpreted by the targeted audience.

Conceptual Background
Policy incoherence has challenged systemic school reform efforts for decades.By incoherence, we refer to the crowded field of mandates, incentives, and reform efforts that pull educators in different directions and at times represent conflicting priorities.States, districts and schools have adopted multiple improvement initiatives, while struggling to boost student achievement.Yet the resulting incoherence has strained the capacity of local educators to coordinate and implement programs (Bryk, Sebring, Kerbow, Rollow, & Easton, 1998;Hatch, 2001).Incoherence is linked to a number of inefficiencies and negative outcomes.Lack of coordination amongst elements of a school's instructional program is associated with lower student achievement (Bryk, Sebring, Allensworth, Luppescu, & Easton, 2009;Newmann, Smith, Allensworth, & Bryk, 2001).Shared values and unity of purpose in a school have been shown to be important conditions for student learning (Bryk, Lee, & Holland, 1993;Bryk et al., 2009).In addition, the implementation of multiple improvement efforts at the same time limits the potential of reform policies to meet their objectives (Cohen, 1995;Cohen & Ball, 1996;Elmore, 1996;Newmann & Wehlage, 1995).These negative outcomes stem, in part, from fragmentation of educators' attention, which limits the deep engagement with any given reform program that is necessary to improve teaching and learning (Bryk et al., 1998).
Coherence traditionally implied the alignment of policies and practices, or at least the absence of obvious policy conflicts (Honig & Hatch, 2004).However, increasingly policy scholars have shifted the focus to the process by which members of an organizational system construct an understanding of their collective challenges and develop a strategy for action (Unger, 2008).Honig and Hatch (2004) reframe the idea of coherence as a dynamic process, by which organizations strategically use external demands to strengthen their performance, arguing that schools and school districts should work in partnership to negotiate the fit between external demands and organizational goals.Similarly, Knapp, Bamburg, Ferguson and Hill (1998) argue that when reforms are implemented simultaneously, "It remains to the frontline professional to sort this all out, to make sense of these pressures, and to integrate what is useful into the flow of day-to-day work, while screening out less useful or more problematic demands" (p.409).
Shifting the notion of coherence to a strategic process that actors engage in calls attention to how educators understand and make sense of external mandates.Seashore, Louis, Febey, and Schroeder (2005) conclude that a consistent finding from the implementation literature is that: "When teachers or administrators are confronted with a new policy, their interpretation of it will determine whether they engage in significant change, incremental change, or resistance" (p.178).Consequently, we draw theoretically on a sensemaking perspective, which explains how the meaning of information or events is actively constructed by participants (Coburn, 2001;Porac, Thomas, & Baden-Fuller, 1989;Vaughan, 1996;Weick, 1995).As Coburn (2001) notes, "The meaning of information or events…is not given, but is inherently problematic; individuals and groups must actively construct understanding and interpretations."By sensemaking, we refer to the process whereby teachers' and administrators' interpretations of policy demands result in decisions about how to respond (Seashore Louis et al., 2005;Spillane et al, 2002a).In this study we focus on these interpretations as a key part of the sensemaking process and provide descriptive accounts of the interpretations educators have constructed about how to implement special education policies in the context of standards-based accountability reforms.
This emphasis on sensemaking and cognition has also been applied in prior studies of policy implementation that stress how individuals assimilate or accommodate existing beliefs and practices in light of new demands from policy (Spillane, 2000;Spillane, 2004;Spillane, Reiser, & Gomez, 2006;Spillane, Reiser, & Reimer, 2002b).Studies examining the implementation process detail how principals and teachers interpret policy, which ultimately shapes the way external reforms influence practice in schools and classrooms (Burch & Spillane, 2003;Burch, Theoharis, & Rauscher, 2010;Coburn, 2005;Spillane, 2004).Educators may generate coherent interpretations of policy demands that drive their actions, but their interpretations may also emphasize the inconsistencies inherent in external demands, which in turn breeds cynicism, frustration and resistance (Seashore Louis et al., 2005).
Prior work has noted potential internal inconsistencies with respect to the goals and mechanisms of test-based accountability policies (Au, 2009;Ogawa & Collom, 2000;Rumberger & Palardy, 2003).There is also some, albeit extremely limited, empirical evidence suggesting that educators perceive conflicts between special education regulations and federal accountability mandates (Cole, 2006;CEP, 2005).While studies support the possibility of perceived conflict, they provide little insight into the nuances of how educators make sense of these demands.We begin to address this gap with an exploratory study examining the language educators used to describe their special education programs in an era of high stakes accountability, which we argue provides insight into the cognitive processes underlying their efforts to craft a coherent response.Understanding how educators made sense of dual policy pressures may provide insight into the behavioral responses that result as they implement policy provisions (Spillane et al., 2002a;Spillane et al., 2002b).

Methodology
This exploratory qualitative study sought to: (1) examine the ways in which NCLB and IDEA (as written) are aligned and mutually reinforcing and/or in conflict; and, (2) describe the ways school and district leaders are conceptualizing the issues involved in meeting the needs of students with disabilities in the context of high stakes accountability.
Our data sources included the text of federal special education and accountability policies and regulations, as well as transcripts of annual interviews with a sample of superintendents, principals and teachers across a three-year period in six school districts (2004)(2005)(2006).See Table 1 for more details about the sample.Our interview data were collected as part of a longitudinal study of the implementation of NCLB in California, Georgia and Pennsylvania funded by the National Science Foundation (Stecher et al., 2008).The research team conducted annual visits with a sample of 20 elementary and middle schools in Spring 2004 through Spring 2006.In each of the six districts, the project team visited one middle and two elementary schools every year and conducted interviews with a selection of each school's teachers, math and literacy coordinators and principal.In the first and third year of the study we also interviewed a sample of superintendents in each state.
We followed semi-structured protocols that probed educators' perceptions of the influence of standards and assessments on teaching practices, the school organization, school and district leadership, and students.The protocols were used as a general guide for the interviews and interviewers were trained to ask broad, open-ended questions.For example, teachers were asked questions such as, "Have your teaching practices in [math and/or science] changed in the last few years as a result of the new [state] NCLB accountability system?" and "How useful are the state test results to you?"For this article, we restricted our analysis to exploring how educators interpreted the challenges associated with addressing the needs of students with disabilities while also remaining accountable to NCLB.This work is exploratory because the larger study was not specifically designed to address the interplay between NCLB and special education programs.The implementation of NCLB was the primary focus of these semi-structured interviews and the topic of special education did come up in all interviews.However, the fact that this issue emerged without explicit questioning in 106 out 347 interviews, or 31 percent of interviews, suggests that it is a salient issue for educators and worthy of examination.Our analytic strategy was twofold.First, we analyzed the alignment of NCLB and IDEA as written documents.The policy implementation literature suggests that the design of policies plays a role in their interpretation (Honig, 2006;Spillane et al., 2002b).We identified the following categories from the literature to aid comparison of policy documents (Hannaway & Woodroffe, 2003;McDonnell & Elmore, 1987): aims, objectives and desired outcomes; policy targets; policy levers and incentives; mode of accountability; and pedagogical focus.Analyzing the two policies along these dimensions generated findings about the alignment of policies as written and provided context for understanding educators' perspectives.
Second, we analyzed the interviews with a focus on gaining insight into how educators conceptualized the relationship between the two policies.We used qualitative analysis software (NVivo) to search the full dataset of interviews for instances where issues related to special education students, programs or policies were discussed.This generated 106 interviews for additional analysis.We then followed a general inductive approach to analyze the interviews (Miles & Huberman, 1994;Thomas, 2006).After several readings of the interviews that touched on special education in the context of accountability policy, we developed a set of codes with definitions and decision rules for systematically analyzing the interviews (Boyatzis, 1998;MacQueen, McLellan, Kay, & Milstein, 1998).These codes included the following categories: assessment issues; effects on students; highly qualified teacher status; inclusion; placement of students in schools or programs; policy conflict; fairness; and stigma.The coded passages captured the range of responses to the challenge of simultaneously implementing NCLB and IDEA.For example, we compared the prevalence of responses and interpretations within and across codes by role groups (superintendent, principal, general education teacher, and special education teacher).
After coding the interviews, each author read the coded material and generated themes that sought to capture the range of educators' interpretations of policy demands.We compared the themes generated by each author individually and condensed them into a final set of themes through discussion and careful review of the raw data.Finally, we returned to the policy documents to examine the extent to which educators' perceptions were grounded in specific provisions of either or both policies.We employed matrix displays to examine the relationship between policy provisions and educators' interpretations (Miles & Huberman, 1994).Our findings describe a range of responses, and whenever possible preserve educators' voices in order to provide insight into how they interpreted policy demands, which we suggest is a product of the sensemaking process.
Our investigation has a number of limitations.Since the interviews were not specifically designed to investigate our research questions, the material presented from interviews is offered as evidence of the range of educators' interpretations of the implementation challenges inherent in serving special education students in the context of test-based accountability policies rather than their prevalence or representativeness.Furthermore, the data provide limited insight into educator cognition and interpretation such that we employ educators' descriptions of their responses to policy to surface their interpretations of policy demands.Thus, while we employ a sensemaking perspective, the micro processes of sensemaking are not captured by our study.For example, limited information collected about respondents prevented us from analyzing how educators' past experiences and beliefs shaped the sensemaking process.

Findings
Our findings address the alignment of NCLB and IDEA as written documents, as well as educators' perceptions of alignment in the context of their professional practice.We begin by providing the results of our textual analysis of NCLB and IDEA, which revealed a number of important contrasts in the ways the laws specify provisions for the education of students with special needs.In a subsequent section, we present findings from our interview analysis which describes a range of ways that educators' made sense of the two policies and shows how these interpretations relate to components of the policies as written.

Textual Analysis: Coherence as Written
NCLB seeks to hold schools accountable for the academic achievement of all students as measured by their performance on standardized tests.The Act's purpose is to "ensure that all children have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging State academic achievement standards and state academic assessments" ( §1001).The Act states that this purpose can be achieved by "ensuring that highquality academic assessments, accountability systems, teacher preparation and training, curriculum, and instructional materials are aligned with challenging State academic standards so that students, teachers, parents, and administrators can measure progress against common expectations for student academic achievement" ( § 1001(1)).The theory of action is comprised of three main components.Content and performance standards set goals, which establish expectations for schools, administrators, teachers and students; assessments establish a means for judging student and school progress in goal attainment; and incentives or consequences motivate administrators and teachers efficiently pursue goals (Stecher, Hamilton, & Gonzalez, 2003).In theory, by requiring states to create standards, assess students on their knowledge of the standards and report scores to the public, NCLB holds schools accountable for student learning which in turn raises expectations and opportunities for all students.
IDEA aims to ensure that students with disabilities are provided with individualized educational supports and services.IDEA mandates the implementation of a legally binding document that specifies an individualized educational plan (IEP) based on the needs of the student.The theory of action is based on the notion that providing students with disabilities legal rights and protection will compel states, schools and schools districts to ensure that students with disabilities receive a free and appropriate education (FAPE) in the least restrictive educational environment (LRE).The IDEA 2004 regulations state that "special education means specially designed instruction, at no cost to the parents, to meet the unique needs of a child with a disability" (Sec 300.39 (a)(1)).Specially designed instruction is defined as "adapting…the content, methodology or delivery of instruction to address the unique needs of the child that result from the child's disability; and to ensure access of the child to the general curriculum, so that the child can meet the educational standards within the jurisdiction of the public agency that apply to all children" ( § 300.39(b)(3)).
Comparing NCLB and IDEA along five standard policy dimensions reveals a number of key contrasts (see Table 2).First, NCLB primarily focuses on specifying the outcomes of the educational system, while IDEA focuses on the educational process or inputs.NCLB seeks to raise the academic achievement of all students to a prescribed level; IDEA hopes to ensure students with disabilities have access to a free and appropriate education in the least restrictive environment.Second, NCLB is broader in scope-it targets the academic achievement of all students, while IDEA specifically targets students who have an identified disability.Third, both policies hold schools and school districts accountable for enacting particular practices, but the focus of accountability for NCLB is on outcomes and student achievement, while IDEA aims to ensure that schools and districts comply with process-oriented regulations such as procedures for placing students in particular learning environments and the annual documentation of their progress toward learning goals.Finally, the pedagogical focus underlying the two policies is substantially different.NCLB promotes standardization through its introduction of common content standards and assessment.It also offers incentives to ensure that, eventually, all students achieve a minimum level of proficiency on standardized measures.IDEA's core philosophy, however, focuses on the development of an individualized education plan for students with special needs and the delivery of "special designed instruction," "to address the unique needs of the child."The most recent reauthorizations of IDEA in 2004 brought the two policies closer in alignment.NCLB and IDEA are coherent as written in that they both create incentives for schools to expose students with disabilities to grade-level curriculum.As originally implemented, IDEA focused on procedural compliance, instead of monitoring identified students' achievement outcomes (Zigmond & Kloo, 2009).The 1997 reauthorization of IDEA represented a shift toward an emphasis on academic standards and results by mandating that students with disabilities were to be included in state and district-wide assessments.
NCLB bars the exclusion of students with disabilities from state accountability provisions.It mandates that state assessments results for students with disabilities be reported as part of both the total student population and as a disaggregated subgroup.Like IDEA, NCLB permits the development of an alternate assessment based on alternate achievement standards.It allows classification of students as proficient, basic and below basic so their results can be aggregated with those of other students.The law further stipulates that only one percent of students can be counted as proficient based on their performance on the alternate assessment.The 2004 IDEA reauthorization reiterates the mandated inclusion of students with disabilities on state and district assessments.
Federal special education and standards-based accountability policies have sought to increase students' exposure to the general education curriculum and hold schools accountable for the achievement of students with disabilities (Zigmond & Kloo, 2009).Significant differences in the pedagogical focus, accountability provisions and specific instruments of each policy, however, create the potential for incoherence in educators' interpretations and responses.

Interview Analysis: Educators' Sensemaking about Coherence
The educators we interviewed about their implementation of No Child Left Behind identified a number of ways that accountability and special education policies intersect.Our analysis identified three primary ways that the educators made sense of the dynamic interplay between policies that provide insight into how they construct an understanding of implementation demands.These patterns also reveal relationships between how policies are written and educators' interpretations.NCLB and IDEA offered consistent and specific guidelines with respect to the definition of highly qualified teachers, and educators reported a clear and accurate understanding of these policy demands.On an issue where there was no specific guidance from NCLB-the placement of special education students-educators interpreted the law as promoting the inclusion of more students in general education courses, often to an extent that contradicted the clear guidance offered by IDEA.With respect to fundamental issues of teaching and learning, NCLB and IDEA represent contradictory theories of action and educators perceived conflict and expressed concerns about unintended consequences.
Specific and consistent guidelines: Defining highly qualified teachers.Educators understood that both laws demand that teachers meet a particular definition of "highly qualified status," and their reported understanding of the policy demands was generally consistent with the guidelines specified by NCLB and IDEA.Their understanding of how the policies defined highly qualified status may stem from the fact that NCLB and IDEA specify similar and explicit requirements for teachers, enabling little room for variation in educators' interpretations.In this way, educators' sensemaking involved constructing an accurate understanding of the relatively direct guidelines provide by the two policies.NCLB defines a highly qualified teacher as one who has a bachelor's degree, full state certification and demonstrated knowledge of each subject they teach.The 2004 reauthorization of IDEA was aligned with this definition saying, "For any special education teacher, the term 'highly qualified' has the meaning given the term in section 9101 of the Elementary and Secondary Education Act" ( § 1401(10), A).
While respondents displayed a consistent understanding of the highly qualified teacher requirements, educators still framed this area as an implementation challenge.A number of district and school administrators noted that highly qualified status requirements are particularly problematic for secondary special education teachers.They correctly understood that the law mandates that teachers must be certified or meet rigorous state standards for each content area in which they provide direct instruction.For a self-contained secondary school special education teacher, this required certification in mathematics, English, social studies, and science.Two superintendents reported that they were moving toward full inclusion of special education students as a direct response to this challenge.A Georgia superintendent described the logistics saying, "the lines are going to blur as we move away from less and less self-contained populations…we're teaching Algebra I in 8th grade and it's hard to get a special ed teacher with an algebra or mathematics background."And a Pennsylvania superintendent expressed his frustration saying: With respect to special ed certification, in essence we have given up at the secondary level.We feel that is no way we will ever be able to get our special ed teachers at the secondary level properly certified.I think that is designed to be impossible and is impossible to accomplish.In the case of highly qualified teaching requirements, educators viewed mandates in IDEA and NCLB as consistent, but expressed frustration with the feasibility of implementation.The primary way that education leaders reported crafting a coherent response was to move more special education students into mainstream classrooms so that they did not need to take actions that would ensure special education teachers met more stringent qualifications.
Complementary reinforcement: A mandate for full inclusion.School and district administrators made sense of special education and accountability policies as promoting the inclusion of more students with disabilities in mainstream classes.In this case, educators' interpretations are not tightly aligned with the explicit guidance provided by the policies, but rather something they attributed to the policy where there was no outright guidance.No federal education policies mandated inclusion.NCLB, IDEA and the 2004 reauthorization of IDEA contain no direct references to "inclusion" or indirect descriptions of mainstreaming more students.In fact, NCLB is silent with respect to the process by which students with special education needs are educated.The 2004 reauthorization of IDEA promotes exposing students to the general education: Almost 30 years of research and experience has demonstrated that the education of children with disabilities can be made more effective by having high expectations for such children and ensuring their access to the general education curriculum in the regular classroom to the maximum extent possible (p.118, Stat.2649) However, IDEA 2004 continued to emphasize that students should be placed in the "least restrictive environment" given their individual needs and goals.The least restrictive environment is defined as the opportunity to be educated with non-disabled peers, to the greatest extent appropriate given a students' individual needs ( § 300.114).While the LRE may be a general education classroom for many students, IDEA continued to support the notion of a continuum of special education services, including special classrooms and schools.
Despite the lack of explicit policy promoting inclusion, educators across states and districts described pressure to include more students with disabilities in mainstream classes.One California middle school principal was under the mistaken belief that the federal government had mandated that all special needs students be "fully included into general education classrooms" by the start of the 2006-07 school year.A superintendent in Georgia noted: One of the things that I have seen and that has been a really good thing [about NCLB] is the mandate to do an inclusion model with the special education students.Although not all of our special education students have caught up, and I know it's supposed to happen, but I am not certain it will.But I can say that some kids were stigmatized as kids who would never make it … the change in special education has been the biggest benefit of NCLB.Comments such as this suggest that some educators made sense of NCLB as mandating the full inclusion of special education students.
In other cases, educators' interpretations of NCLB as promoting inclusion tended to link test-based accountability targets for special education with the need to expose students to the general education curriculum.No Child Left Behind specified that schools report the percentage of special education students that scored at the proficient level on achievement tests in mathematics and reading as a subgroup.For a school to meet Annual Yearly Progress (AYP) targets, its special education students must meet the same proficiency levels as other students.For example, one California superintendent said, "Every effort is made to keep them [special education students] included in the general education classroom as much of their school day as possible."A superintendent in Georgia also noted: If there's one thing that NCLB has forced us to look at its inclusion.We're responsible for subgroups and the one subgroup we've been having the most trouble with is special education.We've had a 'feel good' special ed program for too many years in this system.Inclusion is a way of bringing that special ed class, that student from a self-contained special ed class back into the regular ed class like it was 40 or 50 years ago.This superintendent added that inclusion has been effective because test scores have increased.When asked to explain those increases he replied: We held those kids to a different standard, a less strict standard.In the inclusive classroom they are held to the same standard as everybody else.They can do it.In most instances they can do it.They might not be able to do it in the same time frame but they can do it.It's been good for their self-esteem and it's helped us.Whether conceptualized as a direct mandate or not, a number of district leaders crafted a coherent response to pressure from special education and accountability policies by including more special education students in general education classrooms.
Having embraced inclusion as a coherent response to dual policy pressures, educators identified a number of beneficial consequences related to greater integration between general and special education programs.A special education teacher in Georgia noted: No Child Left Behind is very good for the regular teachers, because now they have these special education students in their classroom and they are learning how to make modifications…NCLB is very beneficial and very helpful for us, because now, they can't just push us to the side.They're going to bring us and welcome us and we're going to work together as a team.When asked what changes had been made in his district because of NCLB, another Georgia superintendent replied: Collaboration with special ed has changed.It used to be in the department of student services and now special ed is in the department of teacher and student learning…Now more schools are [inaudible] inclusion as a way of instruction where the special ed teacher goes into the classroom so special ed is going into the classroom rather than being pulled out.
And a California middle school principal noted: I feel our RSP [resource specialist program] students are going to have much higher test scores this year and I feel much higher grades than they have previous because they're getting much more one-on-one help in all of their classes.And that peer pressure of having to behave properly sometimes comes up.Children with special needs get frustrated and they act out.They're not doing it very much.Very interesting how peer pressure works.In sum, despite no direct policy support for this interpretation, interview data suggests that some educators, particularly district leaders, made sense of NCLB as promoting the inclusion of special education students, and took actions to achieve coherence by placing students in general education classrooms.This interpretation is likely due in part to the implementation demands of NCLB, including provisions that hold schools accountable for the annual performance of their special education students as a distinct subgroup.
Contradictory instructional theories of action: Frustration and unintended consequences.Superintendents generally expressed enthusiasm about the inclusion of special education students in general education classes.However, special education teachers, who were the most directly responsible for the implementation of special education policy, were the most likely to make sense of IDEA and NCLB as conflicting mandates and identified negative consequences associated with the interplay between policies.The way teachers talked about their implementation challenges suggests that their sensemaking was influenced by the different instructional theories of action associated with each, as well as by teachers' roles as implementer of the instructional program.NCLB promotes standardization because it required states to create common content standards and assessments, as well as sanctions and incentives to ensure that over time, all students achieve a minimum level of proficiency on standardized measures.In contrast, IDEA's core philosophy focuses on the development of individualized education plans for students with special needs.Faced with implementing two contradictory instructional theories of action, educators made sense of the goals specified for special education students by NCLB as unrealistic and feared that special education students would be blamed if their schools failed to meet accountability targets.As a result, teachers struggled to craft a coherent policy response, which led to frustration and professional conflict.
Special education teachers were most likely to see an outright conflict between NCLB and IDEA.A teacher of a self-contained special education class noted: Are  I'm pushing -what I'm I pushing [them] to do? Am I pushing to meet PSSA (state) standards and things I know are going to be on the PSSA test (annual state assessment)?Am I pushing to meet the curriculum that the school district has put forward -which is pretty much aligned with PSSAs, but its got its own calendar and it's own pace.Or am I pushing to meet the child's Individual Education Plan program?So a lot of these are in conflict because as far as their IEP is concerned, and their individualized instruction based on their performance, maybe I should be teaching this person how to subtract with regrouping.But I'm supposed to be doing these expanded word problems because they're not going to have subtraction on a fifth grade PSSA math assessment.They're going to be at more advanced concepts.But I can't reach an advanced concept if they can't subtract.I can't teach division without them knowing multiplication and subtraction because it's in there.At the root of these comments are the conflicting ideologies underlying the policies: IDEA's pedagogical focus on individualization and NCLB's promotion of standardization.A Pennsylvania superintendent eloquently explained: I mean quite frankly, we are all different in terms of our ability to master academic skills so when you have a law that says on one hand, IDEA which is special education legislation, that we must provide an individual education program for children who are diagnosed with learning disabilities and on the other hand NCLB says we have to test all students based on their placement in their grade level and using the same tests.So you have two pieces of legislation we must comply with which contradict each other.These comments and others suggest that teachers had real unanswered questions about how to craft a coherent response to instructing special education students in the context of accountability demands.
The tension between individualization and standardization manifested most dramatically with respect to NCLB's annual assessment requirements.Teachers noted that administering state assessments to special education students based on their age specified grades as mandated by NCLB was problematic because special education students tended to perform significantly below grade level.One special education teacher described the conflict, saying: But the problem of No Child Left Behind is that I see them being tested continuously but not on their present level of instruction, but on their grade level.So the tests are not reflecting to me what they're really learning.So it's assessment without a purpose.It's assessment for data collection, but it's not assessment that will drive my instruction so I have to go back and reassess to drive my own instruction, to make sure they're moving toward meeting grade level standards.A teacher of deaf students noted this conflict and worried about the harm it may cause to students: For reading on a third grade level, it [the state assessment] was a complete waste of time to sit there and say, okay, read this passage and answer the questions, finish all this reading… and they can't even read what the title is about.There is no comprehension going on in those reading passages.But we have to give it because the state tells us that we do…So it makes it very frustrating for them and for the teacher, because they know they can't do it.And it reaches a point of being -they have low self-esteem.At the end of every week, after testing, they don't feel good about themselves because they know they can't do this and they know their hearing peers are supposed to be able to, and they know they can't.And that's a horrible thing to do to a child.Horrible.These teachers felt forced to engage in inappropriate educational practices to comply with NCLB's testing requirements.The data generated by accountability tests is central to the test-based accountability theory of action: data is intended to guide teachers' instructional decisions.However, these special education teachers noted that little valid data is generated when students are tested on content far beyond their current educational performances.As a result, teachers engaged in practices that felt meaningless and even harmful to students.
To some extent, assessment-related polices of NCLB may be mitigated by special education regulations that allow up to three percent of all students in a given district to take either the modified or alternative form of assessment (Zigmond & Kloo, 2009).This regulation has been implemented in phases, and was originally a provision for no more than one percent of students (those with the most severe handicaps), so it is not surprising that teachers continued to highlight this conflict.Some respondents seemed unaware of policy provisions that provide for alternative assessments for severely disabled students.For example, a principal in Georgia highlighted this: You've got a kid that literally can't sit in their desk because of his physical handicaps.Can't bubble-in a test, and he's supposed to be able to do it without any kind of modifications.And that's Georgia's interpretation of the law.Other respondents who were aware of the provisions for alternate assessments noted that the cap was far lower than the percentage of students who needed this accommodation.A superintendent in Georgia estimated that the majority of his special education students-which comprised 12% of his student population-probably need to be tested at a different grade level.
Unrealistic.Having made sense of special education and accountability policies as in direct conflict instructionally, a number of educators conveyed a sense of futility when discussing their responses.This futility was particularly evident when they commented on NCLB's expectation that the majority of special education students meet grade level expectations.A superintendent in Georgia noted: I like the idea [of accountability].My greatest hope is we don't throw it all out, because it forces us to look at individual students and groups.I like that.I think that 100% for every child is not realistic.It is a great goal, but it is not realistic.And what it will end up doing is causing all schools to fail and it will make it just that much more difficult to recruit teachers and recruit administrators and all the people you need to have a high performing school system.A special education teacher in Georgia expressed a similar sentiment: Frankly, I just think that it's unrealistic for some students-not all, but some students -who are not on grade level to be expected to test on grade level and pass.Blame.Many respondents felt that their school or district had not made AYP due to the performance of their special education subgroup (specifically, 6 principals and 23 superintendents).This is not surprising given that nationally, the special education subgroup has been a common reason for a school's failure to make AYP (Eckes & Swando, 2009).In some cases, these responses were simply a statement of fact; for example, when a respondent answered a question about why their school failed to make AYP in the previous years.However, in other cases, the administrators' comments raised concerns that special education students would be stigmatized due to their contribution to school failure.Two principals and one superintendent complained that their schools were penalized for having a disproportionate number of special education students.One principal expressed this frustration: "I have a lot of special eds compared to anybody else in the district.And these kids all end up being -they're not my students, not my neighborhood students-they come here, and it's hurt me." Two superintendents reported moving special education students to different schools to try to avoid having a large enough concentration in any school to warrant a special education subgroup.Furthermore, several special education teachers noted feeling pressured or stigmatized by their association with the special education subgroup because these students posed a threat to making AYP.A special education teacher in Georgia expressed this bluntly, "Nobody wants to have our children in our classroom because we bring their test scores down."A special education teacher in California elaborated on this sentiment: Special ed is the albatross of the school.Special ed as a subgroup has never met their AYP.And the special educators, both RSP and special day class teachers, are both aware and feel very stigmatized that there are other subgroups-there's at least two other subgroups at this school that didn't meet their AYP-but nobody focuses on that.Everybody focuses on special ed as the reason we're not meeting our AYP.So there is tremendous pressure.Having made sense of special education and accountability policies as in direct conflict instructionally, teachers struggled to craft coherent responses all while facing significant pressure to meet what they perceived as unrealistic goals, but goals that if unmet, had consequences for their schools.

Discussion
Much has been written about the complexity of education policy implementation (Honig, 2006).Implementation of a single policy requires that educators make sense of policy demands, interpret them in light of their local contexts and craft responses ranging from resistance, to assimilation into existing practices, to whole scale changes in practice (Coburn, 2001;Oliver, 1991;Spillane, 2000;Spillane et al., 2002b).Crafting coherent policy responses in a crowded field of overlapping and at times contradictory programs and mandates adds to the complexity of the implementation process.Given that crafting coherence is a dynamic process through which educators negotiate how to incorporate external demands into their practice (Honig & Hatch, 2004), coherent responses to policy may mean that educators align practice with policy intent but it may also include interpretations and responses to policies that dampen, amplify or alter their original intent.
The complexity of implementing two wide-reaching policies was evident in our study of educators' interpretations of the No Child Left Behind Act and Individuals with Disabilities Education Act.Educators made sense of the interplay between standards-based accountability and special education policies in varied ways, interpreting some dimensions of the two policies as complementary and other facets as contradictory.
Our findings further suggest that the alignment of policies as written may play a role in educators' sensemaking and responses to multiple policy pressures.When educators confronted components of NCLB and IDEA that were aligned as written, the interpretation they constructed tended to be consistent with the intent of the policy.Educators received consistent guidance on the requirements for teacher qualifications and perhaps as a result, they accurately reported policy demands.In general, clear, explicit and aligned demands across the two policies were associated with consistent educator interpretations.
When dimensions of a policy were ambiguous, educators were more likely to construct interpretations that strayed from explicit policy intent.For example, some educators made sense of NCLB as a mandate for full inclusion, despite no explicit guidance on the placement of special education students.In this case, educators' efforts to craft coherent responses to accountability demands related to special education students likely influenced their interpretations.Because schools were accountable for special education students' performance on state tests through their designation as an accountability subgroup, educators were compelled to expose special education students to the general education curriculum so they would be better prepared.In addition, provisions of both NCLB and IDEA that defined what it means to be a "highly qualified teacher" had the perhaps unintended consequence of making it more difficult for districts to staff selfcontained special education courses because teachers needed certification in the subject matter they were teaching.As a result, district leaders crafted a coherent response to the policies that included mainstreaming more special education students.
Finally, when teachers were challenged to craft a coherent response from conflicting instructional theories of action represented in NCLB and IDEA, it was NCLB with its clear consequences for schools (AYP ratings tied to sanctions) that tended to take precedence.Teachers reported being compelled to pressure students to meet age-based content standards that far exceeded students' academic performance levels and were inconsistent with their Individualized Education Programs (IEPs).As a result, special education teachers reported engaging in actions that conflicted with their professional judgments and worrying about the ensuing negative consequences for students.Taken together, these findings suggest that the specific provisions of NCLB and IDEA influenced educators' interpretations and ultimately the way policy influenced their practice.
In general, our findings also suggest that variation in policy interpretations relates to the role educators play in the educational system.Special education teachers were more likely than school or district administrators to experience NCLB and IDEA as conflicting mandates, perhaps because of the policies' opposing pedagogical theories of action: standardization versus individualization.Teachers, faced with crafting a coherent pedagogical response in their classrooms, noted the challenges associated with implementing conflicting mandates and experienced frustration and fears that students suffered unintended consequences.District leaders were more likely to discuss administrative and staffing issues such as mainstreaming students and reallocating teachers roles to support students in general education classrooms.This finding is consistent with the sensemaking literature, which suggests that a person's interpretations are shaped by their beliefs and prior experiences (Spillane & Jennings, 1997;Spillane, 1999;Vaughan, 1996;Weick, 1995).It is not surprising that educators see coherence through the lens of the classroom while superintendents view it through the perspective of system management.

Implications for Research on Policy Implementation
Taken together, our findings have implications for policy implementation particularly when investigating multiple overlapping policies.The findings suggest a number of propositions that could be examined in further research and applied to other cases.First, clear and unambiguous mandates may be more likely to lead to shared and accurate interpretations.In the case of consistent mandates defining highly qualified teachers, educators largely articulated accurate understandings of policies.Second, when educators face common expectations for broad but ambiguous policy goals-such as the goal that students be exposed to more general education content-then educators may form shared understandings but not necessarily accurate interpretations (e.g., interpreting NCLB as a mandate for full inclusion).Finally, when policies specify theories of action that diverge-such as requirements that students be tested at grade level but educated to pursue goals based on their skill level-educators experience confusion and conflict.This in turn may result in varied interpretations, potentially inducing responses such as disengagement, defeatism or attempts to game the system.
Future research examining these propositions can expand their explanatory power by exploring how educators' interpretations of policy are shaped by interactions between the specific features of policies as written as well as individual and organizational factors.The nature of our study did not permit investigation of how educators' experiences and dimensions of organizational context shape sensemaking alongside the interplay of policies as written, though our findings suggest these factors matter.We found that interpretations tended to vary by educators' roles in the system (e.g., administration versus teaching), which is consistent with research documenting how educators' construct understands of policy messages through the lens of their prior practices, experiences and worldviews (Coburn, 2001;Cohen & Peterson, 1990;Spillane, 1999;Spillane & Jennings, 1997).Prior research also suggests that schools as organizations mediate the sensemaking process through their cultures, leadership, collegial interactions, and resources (Coburn, 2001;Coburn, 2005;Dutro, Fisk, Koch, Roop, & Wixon, 2002;Seashore Louis et al., 2005;Spillane et al., 2002b).Considering organizational context would also extend and elaborate our propositions.

Implications for Special Education Policy and Practice
This investigation also has implications for special education leadership and practice.Our findings contribute to a very small body of research on the interplay between special education policies and accountability policies, by identifying concrete ways that educators have conceptualized the challenge of crafting coherent responses to two policies that are not seamlessly aligned.Our analysis suggests that educators' experiences with test-based accountability policies such as NCLB have reinforced the trend in special education practice toward including more students with disabilities in general education classrooms for greater proportions of their school days (Browder, Wakeman, & Flowers, 2006;Snyder & Dillow, 2011).By holding schools accountable for the extent to which students with disabilities have learned grade level content, schools have an incentive to increase students' exposure to the general education curriculum.In addition, NCLB's provisions related to teacher qualifications encourage schools to alter traditional special education staffing models and move away from self-contained classrooms, which has resulted in more students placed in general education classrooms.The full inclusion of special education students is a controversial issue, and there is conflicting research evidence about the efficacy of this approach for promoting student learning (McLeskey, Hoppey, Williamson, & Rentz, 2004;Williamson, McLeskey, Hoppey, & Rentz, 2006;Zigmond & Baker, 1995).What is clear from the literature is that successfully including students is a complex organizational and practice challenge that requires careful planning and ongoing monitoring and improvement (Burstein, Sears, Wilcoxen, Cabello, & Spagna, 2004;McLeskey & Waldron, 2006;Nolet & McLaughlin, 2000;Scruggs & Mastropieri, 1996).As such, it is important that we consider how policies may unintentionally promote trends in the placement of special education students.Districts should also critically assess their abilities to effectively support students in general education settings.
The challenge of successful inclusion may be exacerbated by some of the ways educators have made sense of special education in the context of high stakes accountability.Special education students are often the subgroup that causes schools to miss accountability targets, which may result in students with disabilities being stigmatized.Some districts in our study responded to these outcome pressures by implementing policies that may not have served the educational needs of students, such as moving students away from neighborhood schools to avoid subgroup concentrations.While our study does not allow us to assess the prevalence of this trend, it suggests an issue to monitor in special education programs.
The future of test-based accountability is uncertain.The federal Department of Education has given some states waivers from NCLB regulations and as a result, schools and districts will likely have greater flexibility in how they implement accountability provisions.Nonetheless, our findings suggest that accountability policies have influenced how educators made sense of special education policy and practice in ways that may persist even if NCLB is repealed or radically altered.Responding to the dual pressures of meeting the needs of special education students in the context of accountability for all students' learning outcomes, educators made structural changes to the education system-including more students in general education courses and moving special education teachers out of self contained classes-that may last beyond current policies.These complex policy pressures and responses suggest that further research is needed to explore this dynamic interplay over time.

Table 1
Interviewees by Role and State

Table 2
we not in some ways with No Child Left Behind violating IDEA and ADA (Americans with Disabilities Act)?I mean the two rules are not…one says teach them at their present instructional level and the other one says only grade level.And I'm going, 'How do I do this?'And they're both laws.And they're both on the books.And I'm mandated to do this.Another special education teacher stated:They have not ever said what we're supposed to do here.You have an IEP and federal law.You're supposed to be able to teach them on grade level.And here's another law that says, well you know what, here's the standard.So how do you do that and nobody can tell us what's okay, what we are supposed to do.What are we supposed to do? Teachers' descriptions of the conflicts between the two policies generally focused on what constituted appropriate goals for students: students' individualized IEP goals or their age-based grade level standards.As one Pennsylvania teacher noted: So during my instruction, I'm putting the extra pressure on them [students], and that's a fine line because I've got to push, but then I've got to back off.Technically, But it is my job, of course, to help them get there but I just think it's unrealistic; I don't think it's fair.A special education teacher in Pennsylvania used a physical analogy to explain this conflict: That all children by the year 2012 will run the forty in six seconds.The child with Multiple Sclerosis.The child with one leg.And you the teacher, you've got to figure out some way to do it or else, you're the teacher, you're failing.And how do you get someone with MS to run a forty in such a time?You can't, you can't.And I think that, educationally, especially with students with learning disabilities, there are achievable goals.You've got to set the bar high, you've got to push the students to do their best, but you can't expect the students to be achieving at these high, proficient levels that are basically set by-I don't how they set those-average.That's my biggest challenge.