A/HRC/4/29 page 17 Legal and conceptual aspects 48. First of all, the Special Rapporteur wishes to point out that many of the countries consulted have national frameworks for the protection of human rights, even if those frameworks do not always take account of persons with disabilities. However, formal legal recognition does not always lead to effective practices that guarantee decent and quality education for persons with disabilities. 49. For those reasons, there is a need for a wide-ranging debate on the meanings and implications of the concepts of “inclusion” and “education for all” in order to ensure that changes in education systems are not merely reclassifications of groups and individuals who are considered to be “different”, but rather introduce new methods of pedagogical interaction between all members of the education community. 50. It should be pointed out that inclusion is not merely the opposite of exclusion. This is why the Special Rapporteur believes that inclusive education involves a radical political and cultural change in education systems. In other words, the system that excludes cannot be the same system that includes or promises to include, since that would imply a mechanism that merely substituted inclusion for exclusion in order to maintain control over excluded groups. One has only to think of the many forms of exclusionary inclusion, such as so-called “integrated education”, which give rise to separation based on the subjective effects of “being included”. 51. In many of the countries surveyed, the role of regulatory legal frameworks and that of the programmes and public policies pursued by some Governments appear to be inadequate. The shortage of available financing and resources and the lack of political will on the part of local government authorities in countries with decentralized administrations appear to be the main factors responsible for the partial or inadequate implementation of policies and provisions aimed at guaranteeing the right to education of children and young people with disabilities. 52. On the basis of the responses received, the Special Rapporteur notes that the vast majority of the countries surveyed have mixed arrangements in which special education schools are combined with the inclusion or integration of students with disabilities in mainstream schools. In most cases, there appears to be a tendency to give priority to educating persons with disabilities in mainstream schools. However, such practices are very ineffectively implemented and their results usually do not meet the aspirations and goals that motivate them. 53. There is almost universal recognition of the need to promote inclusive education practices. However, the concept of inclusive education does not seem to be clearly recognized in all countries, many of which identify it with integrated education. There does not appear to be a consensus on the meanings and implications of the two pedagogical approaches or methods. 54. Some continental trends may be established on the basis of these assessments. In African and Asian countries, the term “inclusive education” is used to refer to the process of incorporating children and young people with disabilities into the regular education system without any reference to integrated education. However, there does not appear to be any distinction between these two pedagogical concepts and trends. In Latin America, both are mentioned as prerequisites for the egalitarian implementation of the right to education of persons with disabilities, but again, no clear differentiation is made between them.