Library: Reasonable Efforts

Reasonable Efforts

• Intro
• Guidelines and Commentary
        Additional Questions and Circumstances that States May Want to Consider
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INTRODUCTION

"Reasonable efforts" requirements were introduced into child welfare proceedings by the Federal Adoption Assistance and Child Welfare Act of 1980, Public Law 96-272 (AACWA). Since the enactment of AACWA, reasonable efforts has been a core concept in American child welfare and practice. The Federal Adoption and Safe Families Act of 1997, Public Law 105-89 (ASFA), maintained but refined this concept. ASFA provides that:

Federal law previously required States to make reasonable efforts to prevent placement and reunify families. It now also requires reasonable efforts to secure a new permanent family when it is not possible either to prevent placement or reunify the family.

These Guidelines are intended to assist States in implementing the procedural aspects of reasonable efforts requirements. Further, they are designed to help States identify and clarify what core services might be appropriate to assure meaningful rehabilitation services for a dysfunctional family and what services are appropriate to assure permanent placement of children unable to safely return home.

Requirements for case plans, administrative reviews, and permanency hearings support the reasonable efforts requirements.

The Federal requirement for reasonable efforts has three major prongs. First, children's health and safety must be the paramount concern in providing and reviewing reasonable efforts. [42 U.S.C. §671(a)(15)(A).] Second, the State agency must make reasonable efforts to preserve families before placing a child in foster care. These efforts are designed to prevent or eliminate the need for removing the child from his or her home and to make it possible for a child to safely return to his or her home. [42 U.S.C. §671(a)(15)(B).] Note, however, that the court may determine that reasonable efforts are not required in certain cases, as explained below. [42 U.S.C. §671(a)(15)(D).] Third, when the child's return home is no longer the appropriate plan, reasonable efforts are required to arrange and stabilize a new permanent home for the child. [42 U.S.C. §671(a)(15)(C).]

The following Guidelines are designed primarily to help States establish criteria and procedures for deciding what services (reasonable efforts) they should provide to preserve or reunify families. For children who are not going to be reunified with their birth families, the Guidelines are designed to help States establish criteria and procedures for making reasonable efforts to find alternative permanent homes. The Guidelines recommend strengthening the courts' oversight both of agency case-by-case efforts to preserve and reunify the family and agency efforts to achieve alternative permanent homes. State laws concerning reasonable efforts must respect parental rights; accommodate children's need for timely, safe, and permanent homes; and observe basic fairness and due process of law.

This chapter provides an overview of the reasonable efforts doctrine, but not all guidelines concerning reasonable efforts appear here. Certain provisions concerning judicial oversight of reasonable efforts within specific stages of the court process appear in Chapter IV, Court Process. Chapter VI, Termination of Parental Rights, includes a discussion of when agencies must prove that they have provided appropriate services to preserve the family, as part of the grounds for termination.

GUIDELINES AND COMMENTARY

Commentary

The reasonable efforts provision was established to limit unnecessary and inappropriate removal of children from their families and to expedite safe reunification of children through the provision of services. Although long an element of Federal law governing eligibility for Federal funds, the reasonable efforts requirement is not always incorporated into existing State law and procedure. The doctrine of reasonable efforts has become a core concept in American child welfare law and practice and should be reflected in State, as well as Federal, law.

Commentary

States should develop criteria for reasonable efforts, a comprehensive catalogue of available services, and administrative and judicial policies to define and operationalize the reasonable efforts requirements. Federal law sets out a policy of reasonable efforts to preserve families, reunify families or find an alternative permanent placement for a child who cannot be reunified with his or her birth family. However, current Federal law allows the States to establish criteria and procedures for implementing a policy that defines reasonable efforts. Federal law also specifies circumstances in which the State may not be required to make reasonable efforts.

What "core services" should a State make available to (a) families in crisis and (b) children in need of a new permanent home? How can the State assure that needed services are provided promptly to prevent placement, reunify families, and find permanent homes for those children not returning to their birth families? By what process should a State decide whether or not to provide reunification services? Under what limited circumstances should the State immediately seek new permanent homes for children without first seeking to rehabilitate the parents? The process should be timely and fair both to children and parents.

State agency policies or regulations should clearly define the agency's obligations to make reasonable efforts to reunify the family. Clarifying these obligations gives the judge a more objective basis to determine whether reasonable efforts have been made and helps child welfare agencies know what is expected of them. State legislatures or agencies could ensure appropriate service delivery by clearly identifying a core of services generally needed by families of abused and neglected children. Once identified, the State legislature or agency could prioritize services by their effectiveness and their costs. The agency would then decide which of those services they could provide promptly to families with children in foster care. Legislatures could require State or local agencies to both develop and deliver this core of services. For example, a core of services might include, among others, substance abuse treatment, time limited counseling services, and in-home intensive services. Such services might also include limited flexible funds that could meet immediate material needs of families. (See M. Hardin, Establishing a Core of Services to Preserve Families Subject to State Intervention: A Blueprint for Statutory and Regulatory Action, 1992; G. Diane Dodson & M. Hardin, On-Time Services to Preserve Families: A Guide for Child Protection Agency Administrators and Policymakers, 1997; Report: Reasonable Efforts Advisory Panel Meeting, National Resource Center for Legal and Court Issues, ABA Center on Children and the Law and the National Child Welfare Resource Center for Organizational Improvement, University of Southern Maine, 1995.)

Though agencies need flexibility to determine the appropriate treatment techniques applicable to an individual family, many agency clients always need certain services. An organized set of these frequently needed services, available in sufficient quantities, will help avoid service delays that hinder timely attainment of permanent homes for children.

Identifying the core of services available for reasonable efforts and designing the criteria and process for determining how the State is to make reasonable efforts is a complex and difficult task. To address these profound issues, States should enlist the assistance of their most knowledgeable people to carefully study the characteristics and needs of children who most often end up in long-term foster care in their State and the needs of the families of those children. One approach is to convene work groups including a range of key experts and stakeholders, to schedule regular meetings of the group, and to plan for that process to culminate in recommended agency policy, draft legislation, and court rules. Such work groups should take into account and not duplicate the State's judicial self-assessment.

Most States have recently conducted careful self-assessments of their courts' performance in child abuse and neglect cases, including the courts' oversight of reasonable efforts. Taking into account the results of the self-assessment, a new State study commission can focus on improving and organizing the delivery of services, implementing the new ASFA requirements, and improving coordination between service providers and the courts.

Commentary

Federal law does not require agencies to make efforts to prevent placement or reunify families where such efforts will endanger a child's health and safety. Federal law states that: "in determining reasonable efforts to be made with respect to a child and in making such efforts, the child's health and safety shall be the paramount concern." [ASFA, §101(a), 42 U.S.C. §671(a)(15)(A).] In addition, reasonable efforts to preserve the family are not required if a court finds that the parent has committed certain serious criminal acts against the child or against another child of the parent, which may jeopardize the child's health or safety. [ASFA, §101(a), 42 U.S.C. §671(a)(15)(D).] Finally, even if none of those specific circumstances applies, courts may exercise their discretion, in individual cases, to protect the health and safety of children. [ASFA, §101(d), 42 U.S.C. §678.] Thus, courts and agencies are not required to make reasonable efforts to preserve and reunify families if such efforts would not be possible without endangering a child's health and safety.

States' obligations to make "reasonable efforts" have sometimes been misinterpreted to require the endangerment of children for the sake of family preservation or reunification. To eliminate such misinterpretations, ASFA makes clear that efforts to prevent removal or to reunify a family are not required when such efforts would endanger a child.

State law should also specify that services are not required when such services might endanger a child's health and safety. State law should make it clear that agencies can respond flexibly in emergencies and when situations suddenly change. Further, it should be clear that when an agency takes such a step it will be considered to have made "reasonable efforts" to prevent placement or reunify the family. Sometimes temporary denials or cessation of services are reasonable.

State law can also make it clear to agencies and courts that service plans should not present undue risks to children. Agencies should not propose and courts should not approve services to prevent placement if those services would place a child in serious danger. Agencies should not persist in providing reunification services where doing so would be harmful or dangerous to the child, and courts should not approve the continuation of such services.

While an agency might not safely be able to prevent removal, it may be able to provide services that will permit a child's early safe return home. When an agency must stop a particular reunification service, other services might be helpful.

Commentary

Federal law requires judicial findings that agencies have made reasonable efforts to prevent the need to remove a child from home or to make it possible for a child to return home safely. [42 U.S.C. §§671(a)(15), 672(a)(1).] State law can assure compliance with Federal program requirements for foster care and implement the reasonable efforts policy more efficiently if it adopts a procedure and substantive criteria in its own statutes or court rules. The court must determine whether reasonable efforts were made at the time a child is removed from home.

To define the meaning of the reasonable efforts obligation, it is helpful to break the obligation into its different elements. The first part of an agency's and court's obligations concerning reasonable efforts is to clarify the reasons for State intervention. That is, before determining whether an agency has made reasonable efforts to prevent the need to remove a child from home or to return the child home, a court must first clarify the danger to the child that required State intervention and document the problems precipitating the danger. Without knowing exactly what dangers prevent a child's immediate return home and what family problems create or maintain a dangerous situation for the child, the court cannot determine whether the agency's efforts to rehabilitate the family were reasonable.

Second, having identified the dangers and problems precipitating State intervention, the court must decide whether the services proposed by the agency are customized to the individual needs and strengths of the family and relevant to the problems requiring placement of the child. To decide if services are relevant, a judge might take into account other services the agency might have offered or possible interim caregiving. In other words, if some other form of available help to the family would have been far more likely to succeed, a judge might determine that there had not been reasonable efforts.

Third, the court must decide whether the agency caseworkers were reasonably diligent in implementing the agency's case plan for the family and the child. Agencies might adopt their own regulations specifying what concrete steps by caseworkers would constitute reasonable casework to rehabilitate a family. For example, the regulations might include the following:

• Caseworkers must closely consult with parents to develop a case plan (using a language translator if necessary) which elicits and takes into account their views concerning services, to make sure the services match their schedules, and to periodically determine whether parents feel that the services are helping.
• Caseworkers must oversee each service provider, explaining to the provider what each service is supposed to accomplish for the family and child, sending a copy of the case plan to the provider, and setting a timetable for each service. The caseworker is responsible for ensuring that the provider adheres to the case plan by checking up periodically with the provider to guarantee that the service is being provided as agreed and that parents are participating.
• Caseworkers must ensure that parents and children have access to services, including arranging for children to be present, when appropriate, and making sure that parents have practical means of transportation, taking into account the resources available to parents.
• Caseworkers must periodically visit children and parents in person as required by agency regulations or policy.
• Caseworkers must arrange for parent-child and sibling visitation.

Fourth, the court must decide whether appropriate services were actually available and delivered on a timely basis to help the family. While it is sometimes difficult for judges to determine whether or not public agencies have been "reasonable" in developing and providing services for families, such a determination is possible. For example, if the child welfare agency has a specific list of services that an agency provides to families, a judge could determine what services on the list were relevant to the family's problems and whether such services were provided to the family on a timely basis.

Commentary

Reasonable efforts to make and finalize a new permanent placement for a child who cannot be reunified with his or her birth family can be broken down into three basic issues. The first issue is whether the agency has identified an appropriate strategy to make and finalize a permanent home. For example, if the child has complex special needs, a judge might ask several questions. Has the agency selected a good specialized placement agency to find an adoptive home and is it offering adequate adoption subsidy and medical assistance protections? Does the agency plan to list the child with appropriate adoption exchanges? Has the agency explored all available families consistent with MEPA? (See generally, J. Hollinger, A Guide to the Multiethnic Placement Act of 1994, as Amended by the Interethnic Adoption Provisions of 1996, ABA 1998.)

The second issue for the judge is whether there has been diligent follow-through to provide those services. For example, a judge might ask the following questions. Has the agency taken timely steps to list the child with appropriate registries? Has the agency diligently searched for potential new parents? Has the agency fully explored whether relatives or foster parents are interested in adopting the child? Has the agency screened and tentatively selected potential new parents? Has the agency taken timely steps to complete home studies? Has the agency counseled and prepared the child for adoption? Has the agency proceeded to prepare adoption assistance agreements (where applicable)? Has the agency arranged for post-adoption services?

The third issue is whether adequate and appropriate services exist to place and stabilize the child in a new permanent home. For example, a judge might ask several questions. Has the agency explored the interest of relatives and foster parents in adopting the child? Is there an available adoption placement agency with specialized skills helpful to this child and a good track record? Does the State adoption agency permit adoption subsidy terms that will provide sufficient and secure services to the child to improve the odds of a stable placement? Does the public adoption agency promise other post-adoption services, as necessary to stabilize the placement?

Commentary

Concurrent planning means working to reunify a family while, at the same time, planning for the possibility that reunification will not succeed. In circumstances where the probability of successful reunification is unlikely, concurrent planning can benefit the child by reducing the length of time that the child is in a temporary placement. For example, an agency might seek out foster parents or potential adoptive parents who will be willing to adopt the child should reunification efforts fail. ASFA explicitly authorizes this practice by providing that "reasonable efforts to place a child for adoption or with a legal guardian may be made concurrently with reasonable efforts [to preserve the family]." [42 U.S.C. §671(a)(15)(F).]

Commentary

Federal law provides that States are not required to make reasonable efforts to preserve or reunify a family in all cases, although State agencies and courts are permitted to extend prevention and reunification services to families even in circumstances where Federal law would not require it.

Most of the above criteria for not requiring reunification services are consistent with existing Federal law. Criteria a through c paraphrase CAPTA or ASFA, and criterion d directly reflects the ASFA exception to the obligation to provide reunification services. Similarly, while the language of criteria e and f was supplied by the Expert Group, it reflects or stands in place of ASFA language, particularly the language related to aggravated circumstances. Criterion g, however, was added by the Expert Group to the criteria already established by Federal law.

The above criteria presume it is highly unlikely that the child can be placed with the parent within a reasonable time even if services are provided to reunify the family. That is, when one or more of the criteria specified in this Guideline apply in an individual case, it is unlikely that reunification services can succeed within a reasonable time.

Under Federal law, States are not required to make reasonable efforts to preserve the family in all cases. ASFA, §101, 42 U.S.C. §671(a)(15)(D) provides that:

[R]easonable efforts [to prevent the need for placement and to reunify the family] shall not be required to be made with respect to a parent of a child if a court of competent jurisdiction has determined that--

Thus, ASFA sets forth certain limited circumstances in which reasonable efforts to prevent removal and reunify the family are not required. These include the commission of certain specified crimes, as set forth above and that parental rights concerning a sibling have previously been terminated. Beyond the mandatory circumstances, ASFA allows States to further define "aggravated circumstances."

Federal law requires a number of the circumstances listed in these Guidelines. Criteria a and b are based on crimes specified by ASFA and the Federal Child Abuse Prevention and Treatment Act (CAPTA), in which "reasonable efforts" are not required. [ASFA, §101, 42 U.S.C. §671(a)(15)(D)(ii); CAPTA, §107, 42 U.S.C. 5106a(b)(2)(a)(xii).] Criterion c invites States to add additional serious crimes, not specified by ASFA, as criteria for not requiring reunification services. Among other things, these might include crimes committed against children other than the child in question or the child's siblings. In particular, it might include crimes committed against another child residing in the child's household.

Criterion d, based on termination of parental rights to a sibling, is specifically required by ASFA as an exception to the obligation to provide reunification services. Some States think this ground is too broad and have elected to define it more narrowly. One way of doing this is to require that the States have made diligent efforts to rehabilitate the family in the case of a prior termination of parental rights.

Criterion e deals primarily with abandoned infants. ASFA and CAPTA require expedited termination of parental rights for abandoned infants. [ASFA, §103(a)(3), 42 U.S.C. §675(5)(E); CAPTA, §107, 42 U.S.C. §5106a(b)(2)(a)(xi)(I).] Since expedited termination is required for abandoned infants, it is also logical to include these as criteria for not requiring reunification services.

Criterion f includes cases in which returning the child home would be an unacceptable risk even if a parent appeared to improve as the result of reunification services. In these cases, there typically is a combination of factors demonstrating the extreme risk to the child. Among these factors are the severity of the harm or threat to the child, the number and frequency of incidents of abuse and neglect, and the particularly cruel or compulsive nature of the parent's acts. The Expert Work Group preferred paragraph f to the language identifying specific examples of "aggravated circumstances" that appears in ASFA (i.e., "sexual abuse, torture, or chronic abuse").

Criterion g involves the situation in which a parent chooses not to participate in services to try to preserve the family and not to accept other assistance. Rather than assuming that parents want to work toward family reunification, agencies should help the parents decide whether this is their goal. Of course, it is essential that the parent is properly counseled and the parent's decision is fully informed.

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Additional Questions and Circumstances that States May Want to Consider

A major area of controversy among the Expert Work Group was the relationship between those circumstances in which reasonable efforts are not required and the grounds for termination of parental rights under State law. At issue was whether the criteria for not requiring reasonable efforts should be the same as certain grounds for the termination of parental rights. States need to consider and carefully debate this area.

The majority of the group thought that the two legal questions (to deny reasonable efforts or to terminate parental rights) were separate and should have their own criteria. A minority felt that certain grounds for the termination of parental rights i.e., most of those termination grounds that do not require reasonable efforts should be criteria for denying reasonable efforts. Whether or not there is a link between grounds for termination and criteria for not requiring reasonable efforts, the State needs to make certain that parents who can benefit from services will actually receive them and that parents' rights to due process are fully honored.

An additional area of controversy among the Expert Work Group related to additions to the criteria listed above. Several additional suggestions received some support within the Expert Work Group but were opposed by the majority. States considering such possible additions should approach them with caution, allowing thorough debate concerning their practical implications. The legislature should be convinced that any criteria it enacts for not requiring reasonable efforts will apply only in situations where reunification services clearly cannot help parents improve within a reasonable time. The following are the additional minority suggestions:

Commentary

To ensure careful judicial deliberation concerning reasonable efforts, it is important to design a process which takes into account the agency's capacity to prepare substantive material in a timely manner and the time the court needs for review and deliberation. A report from the agency, submitted well in advance of the hearing, allows the parties to consider carefully whether reasonable efforts were made. If appropriate, it also allows them to introduce other evidence. A sworn statement helps ensure the accuracy of the report. This recommendation also appears in the Resource Guidelines: Improving Court Practice in Child Abuse and Neglect Cases. (The Resource Guidelines were first published by the National Council of Juvenile and Family Court Judges (NCJFCJ) in 1995 and have been endorsed by NCJFCJ, the American Bar Association, and the Conference of Chief Justices.)^*Equally important is a careful thought process by the judge. The preparation of findings helps ensure thorough judicial deliberations. The findings also provide an authoritative record concerning the agency's efforts. This record can be invaluable in later hearings, including hearings on whether to return the child home or whether to terminate parental rights.

Much of the content of this Guideline is also covered in Chapter IV, Court Process, in the discussion of disposition, review, and post-termination of parental rights review hearings.

Commentary

The Guidelines recommend allowing any party to file a motion, at any time, asking the court to find that the criteria for not requiring reunification services are met. Such a motion might request the finding with regard to one or both parents. Thus, the State or child's attorney might choose to file directly for termination of parental rights at the beginning of a case. Or, after a period of reunification services, one party or another, or the court on its own motion, could move to suspend such services and move to termination of parental rights, guardianship or some other permanent plan for the child. Chapter VI, Termination of Parental Rights, recommends that a petition for the termination of parental rights may be filed at any time. Related matters such as a permanency hearing, a motion to excuse reunification services, or a petition for termination of parental rights should be consolidated and heard together to avoid duplicative proceedings.

Agencies and courts need enough information, early in each case, to determine whether circumstances exist in which reunification services are not required. Legislation may be necessary, for example, to authorize or require checks of parental criminal records when they have abused or neglected their children. It might be needed to allow agencies to review parents' mental health records and other background information, and to allow agencies to obtain speedy court orders, when necessary, to gain access to this information.

When an abused or neglected child enters foster care, the parties and the judge should routinely consider the possibility that reunification services might not be appropriate. Legislation or court rules may, for example, assure that parents are consistently asked whether they want reunification services. They may encourage parties to say (or judges to ask) whether reunification services should be required; specify at what stage these questions should routinely be asked; and authorize the judge to require further information to aid in a decision on whether reunification will be required.

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