This editorial briefly asks this question, wondering where the opportunities are for disabled athletes in the educational system and suggests that instead of being placed under special education, activities like wheelchair basketball should be under athletics like other sports. Or it recommends making sports into club activities which include disabled athletes. It is an interesting discussion--one that is not raised nearly enough--especially when we are speaking of student-athletes instead of elite level athletes who compete at the national and international levels.
*The answer is likely, no. What the editorial really illustrates is that a law that perhaps combines the philosophies of both Title IX and the Americans with Disabilities Act might be beneficial to disabled athletes.