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Mey A. van Munster, Laureen J. Lieberman and Michelle A. Grenier

research has investigated different instructional approaches in PE. In recent decades, the emphasis in PE has remained on differentiated instruction (DI), which is tailored to meet specific needs of the SWD through curricular modifications and instructional adaptations. Willis and Mann ( 2000 ) described

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Melinda A. Solmon

with students, so the best path for them was to seek ways to avoid confrontation. One way to avoid it was to make curricular modifications that, to some degree, were concessions to student noncompliance, effectively avoiding the content. Ennis ( 1996b ) pointed out, however, that confrontation could be