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PL 99-457 requires early interventionists working with handicapped infants to provide case management services as a part of each Individualized Family Service Plan. Although well-intentioned, the case management requirement necessitates skills for which few early childhood special educators are adequately trained. Furthermore, it raises significant issues regarding policy implementation. This article reviews case management from the historical perspective, describes research on case management, and discusses policy issues related to implementing case management in the context of early intervention.