The courts have determined that for some handicapped children to derive "educational benefit" from their schooling an extension of the school year, beyond the traditional 180 day school year, may be required. The current study describes Extended School Year (ESY) program implementation in the field, in the Commonwealth of Virginia, and identifies potential gaps and inadequacies that exist between implementation and case law. A survey instrument was mailed to a purposive stratified random sample of the directors of special education across large and small school districts (with a student population) in the Commonwealth of Virginia. All forty-two of the school divisions surveyed responded to the questionnaire. Data from the survey included descriptive information regarding: the education and training of respondents; services offered to handicapped students beyond 180 days; and criteria for making an ESY determination. A two-year follow-up survey of the same school divisions examined changes in the implementation of ESY services. Survey data were analyzed to reveal points in case law that current practice does not address and practice that is congruent with case law. / Ed. D.