Abstract
The background conditions in each country require that they have a unique history of special education, which has led to different educational systems and services for students with special needs. This study aimed to conduct a comparative analysis of the education laws for students with special needs in the United States and Iran, focusing on the field of learning disabilities and their implementation procedures, and examining their strengths and weaknesses. The research employed a document analysis method, gathering necessary information through extensive search in reputable scientific databases, reports, and published government documents. The special education laws in the United States (up to 2022) and Iran (up to 2023) were compared and analyzed in terms of the changes over time and the implementation processes concerning learning disabilities. Prominent features of the U.S. special education law include individualized education programs, enforcement guarantees, and parental and student decision-making rights in educational matters. However, there is greater emphasis on research project development and scientific investigations in Iranian law. Regarding the implementation procedures and attention to students with learning disabilities, in Iran, support is mainly provided during the early years of education, whereas in the United States, such support continues until the completion of higher education. Additionally, the evaluation of students with disabilities are carried out with greater precision in the United States. Achieving the goals of the law on the rights of individuals with special needs requires not only the completion and approval of legislation but also proper implementation of the laws and structural reforms.
Keywords: Comparative Study, Education Law for Children with Special Needs in Iran and the United States, Implementation Procedures, Learning Disabilities.
 
 
Extended Abstract

Introduction

The contextual conditions in each country require that they have a unique history of special education. The Individuals with Disabilities Education Act (IDEA) is a part of the education rule in the US that has approved the legal process to receive special services for children. In Iran, the law on the education of exceptional children was approved in 1991 by the parliament. Given that learning disabilities is a global issue, it seems necessary to consider it because these children have natural intelligence, but they have severe problems in learning language, reading, writing or solving math problems (Afrozeh et al., 2022) and if diagnosis and reforms are not performed on time, these students will have more problems in higher courses (Shayan, Akhavan Tafti and Ashayeri, 2010). The significance of the study indicates that a few researches have compared the law of education of children with special needs and its implementation procedure in Iran and the US. In this research, the United States has been selected due to its history and progress about children with special needs.
Research Question
Is the low progress of Iran in the fields related to students with special needs, is due to defects in the laws or is it related to the executive procedure in this country?

Literature Review

Historically, special education in the US began in the early 1800s with the efforts of Howe and Gallaudet and has developed considerably since then (Friend, 2013). It is estimated that about 15% of children in the US (Pew Research Center, 2023) have disabilities that are supported by the government under IDEA. Key requirements in IDEA are:
- Free and suitable public education
- Identification and evaluation
- Individual training program
- Minimum environmental restrictions
- Guarantees related to the proceedings
- Participation of parents and students and joint decision-making (Apling and Jones, 2008).
In 1921, the first activities in the field of education of children with special needs started in Iran. But officially in 1991 with the establishment of exceptional education, the institutions started their activities. The goals of the special education organization include:
1) Design the education and rehabilitation system as the mental and physical disabilities of exceptional children are compensated.
2) Continuous reform of exceptional education according to the new methods of education around the world.
3) Considering different groups of exceptional students at different levels.
4) Helping to prevent the occurrence of physical and mental disabilities (Education and Development Organization Charter, 1991).

Methodology

One of the research method types is document analysis and review. The use of documentary research methods includes exploring documents that are related to the subject under study (Creswell, 2012). Documents about a specific subject are one of the data collection methods in the qualitative method (Monadi, 2006). In this research, special education laws in America are related to 1954 until now and in Iran are related to 1920 until now. Descriptive-comparative method is another methodology that was used in this research to adapt and compare the process of changes in special education rules in Iran and America and based on its implementation procedure, it focused on its strengths and weaknesses. Most of the data has been obtained by reviewing the literature and using scientific databases, authentic domestic and foreign magazines and books, and published government reports and documents.

Results

The goal of the researcher regarding the mentioned comparative study is to identify the possible defects of the current laws of Iran and improve their efficiency. The comparative analysis of current laws and procedures in both educational systems is as follows:
Legal commonality:
- Continuous assessment of the work of teachers and trainers
- Implementation of identification and selection plans
- Helping to avoid the occurrence of physical and mental disabilities
- Attention to education in all courses
Strengths of IDEA:
- Considering the details and stages of the educational system, the individual education program, the existence of guarantees related to the legal process, the participation of parents and students in educational affairs and having the decision right, the existence of related services and attention to the issue of student transfer.
The strengths of the law on the education of exceptional children in Iran:
- Paying attention to the development of research projects and performing scientific research, emphasizing the preparation of textbooks and teaching aids.
Executive procedure in the field of learning disabilities:
All the following items exist in the US, but they have not been taken into consideration in Iran, and this indicates the difference in the implementation process of the two countries:
- Provide services in post-primary courses
- Existence of learning disability centers in universities
- The existence of universities for students with learning disabilities
- Considering the monitoring and identification of students with special needs in terms of quantity and quality

Discussion

 Considering the large number of students with special needs, namely learning disabilities, it is expected that there is significant progress and research in this field. They need special support and intervention besides traditional classroom experiences to be successful in school. Paying attention to individual student needs, low student-to-teacher ratio, more opportunities for personal counseling, and the use of individual and diverse educational strategies are among the programs that the educational system in America has taken into consideration (Velog et al., 1989). Therefore, it is important to have effective prevention, monitoring and treatment systems with the participation of specialists from different fields (Grigorenko et al., 2020).

Conclusion

Achieving the goals of the law on the rights of individuals with special needs, not only requires the completion and approval of the law, but also depends on the correct implementation of the laws and the reform of the structures so that it works together with the environmental issues, adaptation of programs and educational management, because ​ only approving the law without executive guarantee does not solve the problem of disabled people.
Acknowledgments
This paper is taken from a doctoral thesis and the authors express their gratitude to all those who collaborated in this research.