Learning and support assistants in inclusive education: a transnational analysis of assistance services in Europe

ABSTRACT This paper presents results of a comparative study about assistance services for supporting students with disabilities in regular schools in five European countries (Austria, Bulgaria, Portugal, Slovakia and the UK). Besides the analysis of relevant documents on assistance services, semi-structured interviews and focus groups with learning and support assistants (LSAs), teachers and stakeholders from the Ministries of Education were conducted. The context of the study was the Erasmus+ project ‘Improving Assistance in Inclusive Education Settings’ (IMAS). The aim of the study was to reveal good-practices, strengths and weaknesses of this service in the five countries. One of the most interesting findings is that Slovakia is the only country with formal and domain-specific qualification requirements for working as an LSA. In line with previous research, further results showed that in all investigated countries, LSAs legally defined roles and responsibilities often do not correspond to their activities performed in practice. Based on these findings, recommendations for improving assistance services have also been provided. These recommendations could support relevant decision-makers in further developing assistance services to ensure adequate support for students with disabilities in regular schools.


Introduction
As stated in the Salamanca Statement, an inclusive school 'must recognize and respond to the diverse needs of their students, [. . .] ensuring quality education to all through appropriate curricula, organizational arrangements, teaching strategies, resource use and partnerships with their communities' (UNESCO 1994, 11-12). Due to a lack of resources, many schools are not prepared to meet these requirements. In particular, a lack of personnel resources (i.e. Special Education Teachers) and a potentially associated overburdening of regular teachers is sometimes linked to negative attitudes towards inclusion (Lübeck 2018). This encourages many schools to employ learning and support assistants (LSAs), also called teacher assistants (Giangreco, Doyle, and Suter 2014), paraprofessionals (Carter et al. 2009) or teaching assistants (Webster et al. 2010). Since assistants perform both teaching and supporting activities for students, we use the term Learning and Support Assistants (LSAs) in this article.
Available empirical data suggest that the employment of LSAs in inclusive schools has increased significantly over the last decades, and some data provide a worrying picture of assistance services (Giangreco, Suter, and Doyle 2010;Sharma and Salend 2016). Scholars have shown that with increasing support from LSAs, the teacher-tostudent-interactions decreased, and it is LSAsnot teacherswho interact with students with SEN, fulfiling the role of their primary teacher (Webster et al. 2010;Butt 2016). This may occur partly due to the unclear roles and responsibilities of LSAs (Sharma and Salend 2016). Moreover, limited collaboration between LSAs and teachers, as well as restricted supervision of LSAs by teachers, have been noticed (Egilson and Traustadottir 2009).
A negative relationship between LSAs' support and students' academic progress has also been reported. In discussing possible explanations, the argument of missing qualification requirements in many countries is often cited. The potentially insufficient level of LSAs' qualification may account for such findings (Webster et al. 2010). Due to this lack of qualification students with Special Educational Needs (SEN) receive instructions from very low-qualified personnel instead of qualified teachers (Carter et al. 2009). Another unintended consequence is that students with SEN often are supported outside their classroom, separated from teachers, classmates and the curriculum (Butt 2016). These factors promote the risk that LSAs contribute to the separation rather than the inclusion of students with SEN (Webster et al. 2010).
These critical results show that caution is needed when implementing such support measures, because it does not always promote the inclusion of children. The question is whether these experiences are similar in different countries, or whether LSAs could assume a different role under different circumstances. To answer these questions, transnational comparisons are necessary. To our knowledge, limited cross-national studies are available. Comparable studies, conducted by Doyle (2007, 2014), provide a short glimpse of LSAs practices in 11 countries (Canada, Finland, Germany, Honduras, Hong Kong, Iceland, Ireland, Malta, Singapore, South Africa, Spain, Vietnam). They collected information about the current status of inclusive education across these 11 countries as well as about LSAs' responsibilities in classrooms. As the authors noted, there is a gap in research that takes the broader (school-wide) context into consideration. Here, a complement as well as an update of the elaborations of Doyle (2007, 2014) is needed.
Therefore, the purpose of the present cross-national comparative study was to report (background) information on support systems across five European countries (Austria, Bulgaria, Portugal, Slovakia and the UK)that have been limited or not considered in studies on assistance services so farand to consider contextual factors, such as legal regulations, as well as governmental guidelines and guidelines from NGOs, that may affect LSAs' roles or status in the school hierarchy. In this context, an initial database research (ERIC) has shown that most of the available data regarding assistances services refer to Northern America, Australia, the UK and Germany, while limited data refers to Slovakia (Vajová and Jarmila 2015) and Austria (e.g.  and no data on LSAs are available from either Bulgaria and Portugal. Therefore, the present results provide unique insights into assistance services across Europe, they reveal similarities and differences across the countries, and moreover, they allow an international perspective on LSAs practices in these five European countries.

The IMAS-project
With the support of Erasmus+ funding programme [Grant number 2016-1-AT01-KA202 -016778], the Improving Assistance in Inclusive Education Settings project (IMAS) was conducted in cooperation with experts from social service providers (SSP) for persons with disabilities from Austria (Chance B), Bulgaria (Agency VISION), Portugal (ARCIL 1 ), Slovakia (TENENET), the UK (CSIE 2 ), the European Association of Service Providers for Persons with Disabilities (EASPD) and the Department for Inclusive Education, University of Graz (Austria). In these countries, LSAs have different names. In Austria, these personnel are called SchulassistentInnen [school assistants]. In Bulgaria they are known as socialen asistent/социален асистент [social assistants]; in Portugal as assistente operacional [operational assistants]. In Slovakia, they are called as asistent učiteľa [teacher's assistants] and in the UK, the term teaching assistants is predominately used.
The project's aim was to analyse five national systems of assistance services with regard to diverse aspects, e.g. LSAs' conditions of employment, their qualification requirements or their responsibilities in classrooms. Based on these findings, recommendations for improving assistance services and, more specifically, for inclusive practices were developed (EASPD 2017). This article presents selected findings from the IMAS-project by addressing the following research questions: (1) In terms of legal regulations, employment conditions, qualification requirements, roles and responsibilities in classrooms, status in school hierarchy and multiprofessional collaboration, to what extent can similarities/differences in assistance services between the countries be identified? (2) Which recommendations can be deduced for improving the assistance service on different (systemic) levels (e.g. policymaking) in order to ensure an adequate support for students with SEN in regular schools?

Method
Data collection and procedure The IMAS-project used a qualitative design involving semi-structured interviews and focus groups. Moreover, a document analysis of legal documents as well as of governmental guidelines and guidelines from NGOs was conducted.
In the first transnational project meeting, differences between national assistance services as well as good-practices, strengths and weaknesses in the five countries were identified by the national experts involved in the project (project partners). During this process, 18 topics of shared importance (e.g. legal status of LSAs, conditions of LSA's employment or qualification requirements) for further investigation were determined.
Based on these topics, guidelines for conducting semi-structured interviews and focus groups with experts were created by the project partners. Additionally, the project partners compiled guidelines for selecting and analysing legal documents (e.g. government policies) and governmental guidelines (e.g. published by Ministries) as well as guidelines from NGOs (e.g. published by the National Council for Special Education) according to the following criteria: (a) focused on learning and support assistants or other related terms for describing support measures for children with disabilities and SEN; (b) related to the education and learning of students with disabilities/SEN; and (c) emphasising inclusive/integrative or general education for primary and secondary level students.
The project partners conducted the document research as well as the interviews and focus groups in the partner countries.

Sample
The sample consisted of experts in assistance services. Experts were selected based on their special knowledge in practical and/or legal implementation of assistance services. The acquisition of the sample (i.e. the quantity of interviewees per country) was left to the national experts from the project group. This led to an imbalance in the sample composition and number of persons interviewed in the five countries.
Overall, interviews and focus groups were conducted with 18 experts. The sample comprised two experienced LSAs from Portugal and Slovakia, both of whom had supported students with SEN in regular primary or secondary schools for many years. In addition, four experts from the management of SSP from Austria, Bulgaria and Portugal and four experts for inclusive education from Slovakia and the United Kingdom were included in the sample. The latter experts had expertise in both developing inclusive educational settings and in providing training for professionals in inclusive education. They also had experience collaborating with stakeholders from the government in the field of education. Furthermore, three stakeholders from the Ministry of Education in Portugal and Slovakia, two experts from the Slovak Institute for Education and one Portuguese expert from a municipality were interviewed about legal regulations of education of children with SEN. Finally, one Portuguese teacher, who coordinated the SEN service in a regular school, and one Slovak teacher, a special pedagogue from a special primary school, participated in the study. Table 1 shows the sample allocated to the five European countries.

Data analysis
All interviews and focus groups were audiotaped and transcribed. The interviewers then summarised and translated the core content of the interviews and focus groups. The most relevant content of the documents about assistance services in the five European countries was also translated and summarised.
The research team from the participating university then analysed the data with directed content analysis (Hsieh and Shannon 2005). According to Mayring and Fenzl  (2019), this procedure is referred to as a deductive category application, in which a coding scheme (category system) is defined in advance on the basis of theory, previous research and requirements of the area of practice. On the basis of the initial coding scheme (18 topics/categories), a coding protocol, including all categories as well as definitions, examples and rules for operationalising the categories, was created by the research team to allow for a replication of the study (Mouter and Noordegraaf 2012). The data were then analysed separately by two independent coders by marking the transcripts using 18 initial categories/codes. Finally, the coders compared their findings, discussed the sparse discrepancies in coding and reached a consensus.

Current conditions of assistance services in five European countries
This section addresses the following issues: legal status of assistance services and related employment conditions; qualification and opportunities for professional development; roles and responsibilities in classroom; status in school hierarchy and multi-professional collaboration. In addition to a cross-national comparison of the findings, detailed information about the current conditions of assistance services in the five investigated countries are presented in tables (Tables 2-5). Thereby, we disclosed the corresponding source of data in the present tables: 'I' stands for interviews/focus groups and the respective references are given, when the information stems from the document analysis.

Legal status, funding and employment conditions of assistance services
The legal status of LSAs varies in different countries and they have different conditions of employment. While there is no specific law on assistance services for supporting students with SEN in regular schools in Bulgaria, the assistance service in Austria, Portugal, Slovakia and the UK is regulated by a number of laws that provide a framework for this type of service. Additionally, there are different legal regulations within particular countries. Because assistance service is regulated at the state level in Austria, for example, the conditions vary in all nine states. In the UK, too, the assistance service differs in the four constituent countries and is regulated by different laws. A further difference appears regarding employment conditions. While LSAs in Austria, Portugal, Bulgaria and Slovakia are predominantly employed by SSP, respective municipalities or Ministries of Education, LSAs in England are hired by schools. The work of LSAs is linked to the definition of students with SEN in different countries. According to the national law from the UK, Austria and Slovakia, a child has SEN if he or she has significantly greater difficulties in learning than the majority of his or her peers and/or is unable to follow the regular curriculum without special support due to a physical, sensory or mental disability and/or chronic disease (Zákony pre ľudí 2008, §2; UK Legislation 2014, §20(1)). In Austria, this disability must also last for a period of more than six months (RIS 1985, §8 (1)). In Bulgaria and Portugal, however, the term SEN is not explicitly and comprehensively defined within respective legal documents. Table 2 offers an overview of the legal regulations, the funding of the assistance service and LSAs' employment conditions in all five partner countries.
Qualification requirements and opportunities for professional development Although there are defined requirements for LSAs in all five countries, most of these only contain general requirements, such as a minimum age. There are no domainspecific qualification requirements for working as an LSA in most of the five countries. This means that most LSAs do not have to complete a specific training programme for supporting students with SEN in their learning. Only in Slovakia do LSAs have to have completed the upper secondary education level or possess a bachelor's degree in pedagogy, making Slovakia unique in this regard. So, this is a very unique situation in Slovakia.
In addition to a lack of qualification requirements in most countries, there are also limited opportunities for professional development. In Austria, Bulgaria, Portugal and the UK, it is mainly the responsibility of institutions to provide further training for LSAs. In contrast, there are various training and workshops available in Slovakia for the professional development of LSAs organised by universities and the Ministry of Education. However, for all of these training programmes, participation is voluntary, and LSAs mostly have to attend such training in their private time. Table 3 highlights the qualification requirements and opportunities for professional development in the five European countries. In the Austrian state of Styria, assistance service is regulated by two laws: §7 of the Styrian Disability Act, which regulates the support of students with SEN in regular schools (RIS 2004a, RIS 2014a, and §35a of the Styrian Law on Compulsory Education, which regulates the support of students with physical disabilities (RIS 2004b, RIS 2014b. In most cases in Styria, non-profit SSP employ LSAs and in some areas, the municipality employs LSAs (I).
Regardless of the employer, both laws foresee that 60% of the costs must be funded by the Styrian state and 40% by the municipality in which the child attends school (RIS 2004a, RIS 2004b. Bulgaria No specific law regulates the assistance service for students with disabilities in schools. The only relevant legal regulation is the law for social assistance that regulates the support of children and young people at home and in leisure time. The Agency for Social Development VISION is the only non-profit organisation in Bulgaria that offers this support for students with disabilities in schools. It operates on this legal basis and it is funded by the Social Programme of the Municipality of Varna (I

Roles and responsibilities of LSAs in classroom
While in the UK and Portugal, LSAs are predominantly supporting teachers in educating and teaching students in a classroom, including those with SEN, in Austria, Bulgaria and Slovakia, LSAs are assigned to one or more children with SEN. Though partly determined by law (e.g. in the Styrian law on assistance service), these roles and responsibilities of LSAs often do not correspond to the roles and responsibilities LSAs perform in practice. This can be attributed to the fact that a clear description of LSAs' duties is missing in the investigated countries. As a result, teachers and parents often have different expectations of LSAs' roles and responsibilities in classrooms and, in some cases, teachers delegate all responsibilities regarding students with SEN to LSAs. This leads to LSAs often replacing teachers and taking over pedagogical and instructional roles, they are actually not responsible or qualified for. Table 4 provides an overview of LSAs' roles and responsibilities in the five European countries. Since no specific legal regulations exist, neither do official qualification requirements for LSAs in Bulgaria. Therefore, the Agency VISION created its own qualification requirements for LSAs. These requirements include specific pedagogical competences acquired by completing a secondary and/ or tertiary education degree in Psychology, Pedagogy or Social Work (I).

Portugal
The support of LSAs is allocated based on student needs (National Council for Special Education 2018). Depending on the educational level of the accompanying child, LSAs must have completed at least this educational level (primary school, lower or upper secondary level). Beside this official requirement, further specific criteria for recruiting LSAs may be considered by some organisations that employ LSAs, such as years of experience, experiences or specific training in the field of special needs and inclusion.
There are different opportunities for professional development of Portuguese LSAs. LSAs have the possibility to join specific training on disabilities and inclusion provided by ARCIL and the public training centre for regular schools (I).

Slovakia
LSAs must be over 18 years of age. They must also have completed either a subject-related vocational secondary school or possessing a bachelor's degree in pedagogy (I). According to the law on educational staff, LSAs must have completed upper secondary education at least (Zákony pre ľudí 2019, §11). Professional development is provided by a range of different institutions, including higher education institutions and educational organisations of the Slovak Ministry of Education (e.g. National Institute for Education, Faculties of Education, Methodological and Pedagogical Centre). These institutions provide in-service education and training on various topics in (inclusive) education primarily for teachers, but also other professionals have the possibility to attend courses on different topics to acquire new knowledge and skills. In addition, Slovak NGOs organise workshops on practical issues of assistance in regular schools (I).

United Kingdom
In the UK, each school sets its own entry requirements for LSAs. As an entry requirement, all LSAs must have general certificates of secondary education (GCSEs) at grades nine to four, including English and maths (I; National Careers Service 2018). Since 2003, there has been an advanced training programme for Higher Level Teaching Assistants (HLTA), which allows LSAs to plan, prepare and deliver learning activities to individual students, groups and whole classes (I; UNISON 2018).
There is no governmental funding to support staff training. The professional development of LSAs is left to each school (I).

LSAs' status in school hierarchy and collaboration with other professions
In Austria, Bulgaria and Portugal, LSAs are employed by SSP that are independent of a particular school. Therefore, LSAs are usually not part of the school-community and, as a consequence, LSAs are often not involved in school conferences or meetings. Conversely, in Slovakia, LSAs are part of the advisory board of the school and in the UK, LSAs are employed by schools directly. In these countries, LSAs are more likely to feel or be part of the school community. However, it must be mentioned that LSAs' involvement in diverse activities of schools differs from school to school and depends on the attitudes of the members of the school-community, even within those countries in which LSAs are part of the school-community. The situation is similar with multi-professional collaboration. Differences in people's willingness for cooperation and openness towards other involved professions were identified in all investigated countries. This influences the quality of multi-professional collaboration. In some schools, LSAs cooperate intensively with other professionals, are involved in various (educational) activities and are recognised as important team members. In others, however, LSAs are excluded from educational activities and team Table 4. Comparison of LSAs' roles and responsibilities in classroom.

Roles and responsibilities of LSAs in classroom Austria
In Styria, the legal regulations of assistance services state that LSAs must support students with SEN by providing nursing and supporting activities. Therefore, LSAs are not responsible for pedagogical activities (I & RIS 2014a). In practice, Styrian LSAs support students with SEN in their learning within small-groups or one-to-one settings, both inside and outside of the classroom. They also provide emotional support and foster social relationships in classrooms (I). Bulgaria The roles and responsibilities of LSAs are covered through the legal regulations of social assistance. Additionally, the Agency VISION designed clear roles and responsibilities for LSAs, employed by their organisation. According to these regulations, LSAs main tasks are to support children with SEN in kindergarten and regular schools, support them in their learning process and participation in school, help them to get involved in local community activities and establish a close relationship with parents, teachers, other social service specialists and interested stakeholders (I).

Portugal
LSAs are responsible for supporting teachers and/or specialists in planning and implementing educational activities with all students, including those with SEN. Further tasks of LSAs are cleaning rooms, maintaining spaces and equipment, preparing rooms for different activities, ensuring student's safety, supporting them in daily life activities (e.g. feeding, toileting and sleeping) assisting with the transportation of students to and from school as well as monitoring the arrival and departure of the children (I). Slovakia LSAs are involved in the creation of conditions for overcoming health and social barriers of students with SEN in the education process (National Council for Special Education 2018). According to this, the main roles and responsibilities of LSAs include interacting with teachers and teaching staff, facilitating the inclusion of the child with SEN in the school environment, co-organising activities for the child during the educational process and conducting pedagogical supervision during breaks. LSAs also support children with SEN during leisure-time activities organised by schools. Further tasks are cooperating and communicating with the families of the supported child and being familiar with the child's health and family environment (I).

United Kingdom
The Department for Education, and the Department for Health (2015) published a guidance ("Code of Practice") for working with students with SEN relating to Part 3 of the Children and Families Act 2014 in England. This guidance sets out that "Teachers are responsible and accountable for the progress and development of the students in their class, including where students access support from teaching assistants or specialist staff" (p. 99). In addition, the Department for Education commissioned nonstatutory professional standards for LSAs, specifying the role of LSAs and their tasks within the educational system. In accordance with these standards, the primary role of LSAs is to work with teachers to enhance the learning and attainment of all students in class, including those with SEN (I; Department for Education 2016a). In practice, teachers often delegate the responsibility for supporting students with SEN in their learning to LSAs. As a consequence, LSAs provide a significant proportion of their pedagogical instruction to students with SEN away from classroom and separated from classmates (I).
meetings. Moreover, in some countries (e.g. Austria), cooperative activities (e.g. LSAs participation in meetings or joint lesson planning) are not considered as working time. This can lead to such activities taking place in LSAs' free time or not at all. Table 5 presents country-specific differences of LSAs' status in school hierarchies.
To summarise, results showed that the current conditions of assistance services in the five European countries vary, even within a country. While in England, LSAs are hired through the school, in other countries, LSAs are mainly employed by school-independent SSP. This has significant consequences for the cooperation between teachers and LSAs. Differences between the countries in LSAs' roles and responsibilities were also discovered. In the UK and Portugal, LSAs are responsible for supporting teachers in teaching all students, whereas, in the other countries, LSAs are assigned to one or more students with SEN. This result is critical due to the fact that legally defined qualification requirements for LSAs only exist in Slovakia. Furthermore, there are limited opportunities for professional development in most countries. LSAs' participation in further training is voluntary and, in most cases, they have to attend such training/courses in their free time. Similar findings have been revealed regarding multi-professional collaboration. In Austria, Bulgaria and Portugal, cooperative activities (e.g. joint lesson planning) are not considered as working time. The quality of multiprofessional collaboration, therefore, depends significantly on the willingness of the involved persons as well as the employers and thus varies from school to school.

Recommendations for improving assistance services on the European level and implications for inclusive education
The present study provides unique findings about current conditions of assistance services in five European countries, gained by interviews, focus groups and document analysis. In this context, similarities and differences across the countries, as well as Table 5. Comparison of LSAs' status in school hierarchy.
LSAs' status in school hierarchy Austria In Austria, the majority of LSAs are employed by SSP. Therefore, they are not part of the school community. This leads to limited possibilities for cooperation with teachers and scarce involvement in school activities. Moreover, Styrian LSAs are assigned to a specific child for a certain amount of approved hours. These hours do not include time for cooperative activities with teachers (I). Bulgaria Since the Agency VISION is currently the solely organisation employing LSAs, they are not a fixed part of the school-community (I).

Portugal
Although LSAs are employed by external organisations, they are recognised as a full part of the schoolcommunity. In addition, a close collaboration between LSAs and teachers as well as other specialists in schools exists (I).
However, lack of time to exchange with other professionals has been identified as a problem (I).

Slovakia
LSAs are part of the advisory bodies, such as members of pedagogical boards and members of methodological associations of schools. Therefore, LSAs are equal members in the schoolcommunity and there is a mutual exchange of information with teachers and other professionals. In addition, most schools employ an official mentor, who advises LSAs (I).

United Kingdom
As provided by the Children and Families Act (2014), all schools in England must designate a qualified member of the school staff as Special Educational Needs Coordinator (SENCO). The responsibilities of SENCOs include the exchange between LSAs, head teachers and governing body as well as with parents, colleagues and further agencies about the accompanied child (Department for Education, and Department for Health 2015). In practice, LSAs recognition in school varies enormously from area to area and from school to school (I).
strengths and weaknesses of the national support systems, have been observed and good-practices have been revealed. Based on these findings, the members of the partnerconsortium created a list of recommendations for improving assistance services in Europe. These recommendations have been developed in a cooperative discussion process and are presented in the following section, enriched with previous research findings to substantiate the arguments.
Provide reliable financial resources for all To avoid the categorisation and discrimination of students with SEN, all students who need support in school should have equal access to resources as well as to assistance services, whether financed by federal, local or regional budgets. Similar to the system provided in the UK, we recommend an index-based resource allocation. This means that every school should receive resources based on certain criteria (quantity of students with SEN, quantity of students and social background of students, etc.; see Bacher, Altrichter, and Nagy 2010). These resources should be managed autonomously by the schools and they should have flexibility in how to use them.
Make LSAs a full part of the school community and provide time for multi-professional collaboration Whether LSAs are employed by schools or by external SSP (both forms of organisation have their benefits), they should be seen as an integrated part of the school community and should be included in all school activities as well as in all relevant communication procedures between students, parents, teachers or external and internal supporters. Additionally, LSAs should be integrated into the class community. All involved professionals, students and their families should work together as a team. Various scholars have identified multi-professional collaboration as a crucial factor for a successful implementation of inclusive education (Devecchi and Rouse 2010). In line with previous findings (Sharma and Salend 2016), our results indicate that time for collaborating with teachers is missing. Various activities, not directly linked to the students' support (e.g. participation in meetings with teachers) are not considered as working time for LSAs. Based on these findings, we recommend that the collaboration between LSAs and teachers should include time for joint lesson planning, for developing adequate resources for students, for exchanging information with teachers, reflecting on lessons and for collaborative problem-solving. All these activities should be part of their scope of duties and should be seen as working time. A strong collaboration will ensure that the needs of the students are met (Biggs et al. 2016).

Define roles and responsibilities
Closely linked to the quality of multi-professional collaboration is the demand for clarifying the roles and responsibilities of LSAs in classrooms, and in some countries for teachers as well. First of all, teachers must be aware that they are responsible for the learning and education of all students in their class, including those with SEN. Corresponding to previous findings (Butt 2016;Peters 2015), a clear description of LSAs' (and teachers') roles and responsibilities would avoid different expectations of parents and teachers towards LSAs. This would also prevent teachers from giving all responsibility for supporting students' academic and social progress to LSAs.
As teachers often feel overwhelmed teaching so many different students in class without additional resources (Giangreco and Doyle 2007), we recommend that the role of LSAs should focus on supporting teachers in teaching the entire class. In doing so, less qualified LSAs would no longer have the main responsibility for supporting students with SEN. This role would shift (back) to the qualified teacher, enabling that all students receive the same high-quality education. Additionally, providing support to all students, not only to those identified as having special needs, might help avoid stigmatising certain children (Broer, Doyle, and Giangreco 2005). These changes would provide individual support for those who need it, without the need to categorise students and would, therefore, promote inclusive education for all (Ainscow 2005).

Define qualification requirements
In order to provide adequate support for children with SEN, LSAs should be specifically trained and prepared for their job. This should become a formal requirement. On the basis of their broad scope of duties, we recommend in line with Carter et al. (2009), that this training should include basic information about disabilities, pedagogical knowledge, instructional strategies and methods for supporting all students' learning and social interactions. It should also focus on the competencies necessary for multi-professional collaboration. Such training would decrease the probability that LSAs have a negative impact on students' academic progress, and make it more likely that they perceive themselves as sufficiently qualified for providing adequate support to students with SEN. According to previous research, there is also a need for preparing (prospective) teachers to cooperate with and supervise the work of LSAs (Webster et al. 2010). Therefore, it seems necessary to also focus on multi-professional collaboration and supervision of LSAs in teacher education.

Conclusion
These recommendations are intended to support decision-makers in political and educational contexts to improve assistance services in European schools. Since the majority of these recommendations are linked to legislative changes and revisions, it is primarily up to the decision-makers to implement these recommendations.
However, the consortium is also striving to continuously improve assistance services for students with SEN around Europe. For this reason, the follow-up-project IMAS-II, funded by the Erasmus+ Programme [Grant number 2018-1-AT01-KA202-039302], aims to develop and evaluate five web-based knowledge boxes focusing on relevant topics of LSAs' support. This flexible training is intended to strengthen LSAs' inclusive competences, to contribute to quality improvement of assistance services and to the success of inclusion in schools (Breyer and Gasteiger-Klicpera In press 2019).
Finally, it must be noted that the support of LSAs for students with SEN is not intended to represent a final solution for an inclusive educational system, but this support measure currently is a pivotal resource for many parents and teachers to avoid separation. Therefore, the present recommendations provide suggestions for improving the current situation in schools (e.g. dealing with missing personnel resources). Here, changes on a systemic and political level are vital to meet the demands of an inclusive educational system. In such a system, all students must be granted equal access to education and thus, not be dependent on the support of a single person.

Limitations
The findings of the present study are limited by some methodological constraints and therefore must be interpreted cautiously. Only a small amount of people was interviewedin two countries (the UK and Austria), moreover, only one person was interviewed. The imbalance of the sample might reflect a subjective view on assistance services and limits the interpretation of the findings. This applies to the UK, because the situation in Austria is very well known to the authors of the study. In addition, the small sample and the imbalance of the sample also limit the reliability and generalisability of the data. In order to validate the results, particularly those of the UK, additional data are needed. This would allow for a more reliable perspective on national conditions of assistance services.
Finally, language barriers are a further limitation of the study. Some of the relevant legal documents on assistance services are only available in the respective national languages. Therefore, the relevant information had to be translated, whereby potentially valuable and additional information might have been lost. Notes 1. Associação para a Recuperação de Cidadãos Inadaptados da Lousã. 2. Centre for Studies on Inclusive Education.

Disclosure statement
No potential conflict of interest was reported by the authors.