Controversy surrounding the provision of psychotherapy as a related service to emotionally disturbed students is examined. Key issues in the question, including definitional issues, economic realities and financial concerns, and the need for related services for educational vs. medical reasons, are analyzed. Interpretations on the topic by state and federal courts, the Office of Civil Rights (OCR), and Special Education Programs (SEP) are presented, along with relevant sections of the regulations for P.L. 94-142, the Education for All Handicapped Children Act, and Section 504 of the Rehabilitation Act of 1973. (Texts of 10 interpretations are appended.) A polarization is noted, in which OCR and state and federal courts consistently find psychotherapy to be a related service within the meaning of the P.L. 94-142 regulations, while SEP has interpreted the law more strictly. Future uncertainty about regulatory and/or statutory changes is seen to further increase confusion on the issue. (CL)