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STATE 

STATUTES

Current Through 

March 2016 

Reasonable Efforts to 

Preserve or Reunify 

Families and Achieve 

Permanency for Children 

WHAT’S INSIDE

When reasonable efforts 

are required

When reasonable efforts 

are not required

Summaries of State laws

To find statute 

information for a 

particular State, 

go to 

https://www.childwelfare.

gov/topics/systemwide/

laws-policies/state/.

“Reasonable efforts” refers to activities of State social 

services agencies that aim to provide the assistance 

and services needed to preserve and reunify families.

Laws in all States, the District of Columbia, Guam, 

Puerto Rico, and the U.S. Virgin Islands require that 

child welfare agencies make reasonable efforts to 

provide services that will help families remedy the 

conditions that brought the child and family into the 

child welfare system. The statutes in most States use a 

broad definition of what constitutes reasonable efforts. 

Generally, these efforts consist of accessible, available, 

and culturally appropriate services that are designed 

to improve the capacity of families to provide safe and 

stable homes for their children. These services may 

include family therapy, parenting classes, drug and 

alcohol abuse treatment, respite care, parent support 

groups, and home visiting programs. Some commonly 

used terms associated with reasonable efforts include 

“family reunification,” “family preservation,” “family 

support,” and “preventive services.”1 

1 Services to be provided to the child and family are specified in a case plan. For more 

information on the case planning process, see Information Gateway’s Case Planning for 

Families Involved With Child Welfare Agencies at https://www.childwelfare.gov/topics/

systemwide/laws-policies/statutes/caseplanning/. 
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When Reasonable Efforts Are 

Required

Federal law has long required State agencies to 

demonstrate that reasonable efforts have been made to 

provide assistance and services to prevent the removal of 

a child from his or her home and to make it possible for 

a child who has been placed in out-of-home care to be 

reunited with his or her family.2

2 Beginning with the Adoption Assistance and Child Welfare Act of 1980 (P.L. 

96-272).

 “Reasonable efforts” are 

made when the child and his or her family are provided 

with services that are relevant to their situation, which may 

include:

 Child care 

 Homemaker services

 Individual, group, and family counseling

 Health-care services

 Behavioral health evaluation and treatment

 Drug and alcohol abuse counseling 

 Parent education

 Vocational counseling

Community-based family support services that promote 

the safety and well-being of children and families also may 

be offered. These services are designed to:

 Increase family strength and stability

 Increase parent confidence and competence 

 Afford children safe, stable, and supportive family 

environments 

 Enhance child development

In many States, the statutes also require that when a court 

determines that family reunification is not in the best 

interests of the child efforts should be made to finalize 

another permanent placement for the child. Under the 

Adoption and Safe Families Act of 1997 (ASFA), while 

reasonable efforts to preserve and reunify families are 

still required, the child’s health and safety constitute the 

paramount concern in determining the extent to which 

reasonable efforts should be made.3

3 States must comply with the requirements outlined in ASFA as a condition 

for receiving certain Federal funds.

When Reasonable Efforts Are NOT 

Required

Under the provisions of ASFA, reasonable efforts to 

preserve or reunify the family are not required when the 

court has determined any of the following:

 The parent subjected the child to aggravated 

circumstances as defined by State law. The definition 

of aggravated circumstances may include, but is not 

limited to, abandonment, torture, chronic abuse, and 

sexual abuse. 

 The parent committed murder of another child of the 

parent. 

 The parent committed voluntary manslaughter of 

another child of the parent. 

 The parent aided or abetted, attempted, conspired, 

or solicited to commit such a murder or voluntary 

manslaughter. 

 The parent committed a felony assault that resulted in 

serious bodily injury to the child or another child of the 

parent. 

 The parental rights of the parent to a sibling of the 

child were terminated involuntarily. 

In all States, the District of Columbia, Puerto Rico, and 

the Virgin Islands, reasonable efforts are not required 

under these circumstances. In addition, several States, the 

District of Columbia, Puerto Rico, and the Virgin Islands 

provide one or more additional grounds for not making 

reasonable efforts. The following are examples of these 

additional grounds:

 The parent abandoned the child (36 States, Puerto 

Rico, and the Virgin Islands).4

4 Alaska, Arizona, California, Connecticut, Delaware, Florida, Idaho, Iowa, 

Kentucky, Maine, Maryland, Massachusetts, Michigan, Mississippi, Montana, 

Nebraska, Nevada, New Hampshire, New Jersey, New York, North Carolina, 

North Dakota, Ohio, Oregon, Pennsylvania, Rhode Island, South Carolina, 

South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, West Virginia, 

Wisconsin, and Wyoming.

 The parent abandoned an infant (11 States).5

5 Alabama, Alaska, Arkansas, Hawaii, Indiana, Minnesota, Nevada, Oklahoma, 

Tennessee, Washington, and Wisconsin.
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 The parent was convicted of murder or voluntary 

manslaughter of the child’s other parent (13 States and 

the Virgin Islands).6

6 Alabama, Alaska, Florida, Indiana, Maryland, Massachusetts, New Hampshire, 

New Mexico, Oregon, Utah, Virginia, Washington, and West Virginia.

 The parent was convicted of the crime of trafficking in 

persons (four States).7

7 Idaho, Ohio, Texas, and Washington.

 The child was removed from the home previously due 

to abuse or neglect and was removed again due to a 

subsequent incident of abuse or neglect (eight States, 

Puerto Rico, and the Virgin Islands).8

8 Alaska, Arizona, Arkansas, California, Florida, Nevada, South Dakota, and 

Utah.

 The parent was convicted of a sexual offense that 

resulted in the child’s conception (four States).9

9 California, Connecticut, Florida, and Washington.

 The parent is a registered sex offender or required to 

register on a sex offender registry (14 States and the 

District of Columbia).10

10 Arkansas, Georgia, Hawaii, Kentucky, Michigan, Minnesota, Nevada, North 

Carolina, Oklahoma, South Dakota, Texas, Utah, West Virginia, and Wyoming.

 The parent failed to comply with the terms of a 

reunification plan (nine States, Puerto Rico, and the 

Virgin Islands).11

11 Alabama, Alaska, California, Florida, Kansas, Maine, Minnesota, Washington, 

and West Virginia.

 The parent has been incarcerated for a substantial term 

in relation to the child’s age, and there is no suitable 

relative to care for the child (seven States).12

12 Alabama, Alaska, Florida, Kentucky, New York, North Dakota, and South 

Dakota.

 The parent suffers from a mental illness of such 

duration or severity that there is little likelihood that the 

parent will be able to resume care for the child within 

a reasonable time (eight States, Puerto Rico, and the 

Virgin Islands).13

13 Alabama, Alaska, Arizona, California, Kentucky, North Dakota, South 

Carolina, and Utah.

 The parent suffers from chronic abuse of drugs or 

alcohol and has refused or failed treatment (nine States, 

Puerto Rico, and the Virgin Islands).14

14 Alabama, California, Florida, Kentucky, North Dakota, Ohio, South Carolina, 

South Dakota, and West Virginia.

 The parent has subjected the child to prenatal exposure 

to alcohol or a controlled substance (three States).15

15 Florida, North Dakota, and Utah.

 The parent indicated a lack of interest in reuniting 

with the child (three States, Puerto Rico, and the Virgin 

Islands).16

16 Alabama, Arizona, and California.

Other grounds found in one or two States include:

 The parent repeatedly withheld medical treatment or 

food from the child (Ohio). 

 A putative father has failed to establish paternity of the 

child (Montana and Nevada). 

 The parent allowed the child to be present where 

a clandestine illegal laboratory is operated (North 

Dakota and Utah). 

 The parent is a convicted sexually violent predator 

(Washington). 

 The parent has abducted the child or a sibling from his 

or her placement (California).

This publication is a product of the State Statutes 

Series prepared by Child Welfare Information 

Gateway. While every attempt has been made 

to be complete, additional information on these 

topics may be in other sections of a State’s code 

as well as agency regulations, case law, and 

informal practices and procedures.

Suggested Citation: 

Child Welfare Information Gateway. (2016). Reasonable 

efforts to preserve or reunify families and achieve 

permanency for children. Washington, DC: U.S. 

Department of Health and Human Services, Children’s 

Bureau.
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Alabama

What Are Reasonable Efforts?

Citation: Ala. Code § 12-15-301(10)

‘Reasonable efforts’ are efforts made to preserve and reunify families prior to the placement of a child in foster care, to prevent or 

eliminate the need for removing the child from his or her home, and to make it possible for a child to return safely to his or her home. 

‘Reasonable efforts’ also refers to efforts made to place the child in a timely manner in accordance with the permanency plan and to 

complete whatever steps are necessary to finalize the permanency placement of the child.

In determining the reasonable efforts to be made with respect to a child, and in making these reasonable efforts, the health and 

safety of the child shall be the paramount concern. 

When Reasonable Efforts Are Required 

Citation: Ala. Code § 12-15-312(b)

As used in this chapter, reasonable efforts refers to efforts made to preserve and reunify families prior to the placement of a child in 

foster care, to prevent or eliminate the need for removing the child from his or her home, and to make it possible for a child to return 

safely to his or her home. In determining the reasonable efforts to be made with respect to a child, and in making these reasonable 

efforts, the health and safety of the child shall be the paramount concern. If continuation of reasonable efforts is determined to 

be inconsistent with the permanency plan for the child, reasonable efforts shall be made to place the child in a timely manner in 

accordance with the permanency plan including, if appropriate, through an interstate placement, and to complete whatever steps 

are necessary to finalize a permanent plan for the child. 

When Reasonable Efforts Are NOT Required 

Citation: Ala. Code § 12-15-312(c)

Reasonable efforts shall not be required to be made if the parental rights of the parent to a sibling have been involuntarily 

terminated or the parent has done any of the following: 

• Subjected the child or a sibling to an aggravated circumstance that made the risk of abuse or neglect too high for the child to 

remain at home or return home. An aggravated circumstance includes, but is not limited to, rape, sodomy, incest, aggravated 

stalking, abandonment, torture, chronic abuse, or sexual abuse. An aggravated circumstance may also include any of the 

following:

» A child is allowed to use alcohol or illegal drugs to the point of abuse, neglect, or substantial risk of harm.

» Substance misuse or abuse, or both, by a parent interferes with the ability to keep the child safe, and the parent refuses to 

participate in or complete treatment or treatment has been unsuccessful.

» A parent demonstrates extreme disinterest in the child by either not complying with a case plan for more than 6 months or 

repeatedly leaving the child with someone who is unwilling or incapable of providing care, and the parent does not return 

for the child as promised.

» An infant or young child has been abandoned, the identity of the child is unknown, and the parent is unknown or unable to 

be located after a diligent search.

» The parent has an emotional or mental condition, and there is clearly no treatment that can improve or strengthen the 

condition enough to allow the child to remain at home safely or to return home safely.

» The parent is incarcerated and the child is deprived of a safe, stable, and permanent parent-child relationship.

• Committed murder or manslaughter of another child or the child’s other parent

• Aided, abetted, attempted, conspired, or solicited to commit murder or manslaughter of another child or the child’s other 

parent

• Committed a felony assault that resulted in serious bodily injury to the child, another child, or the child’s other parent

Alaska

What Are Reasonable Efforts? 

Citation: Alaska Stat. § 47.10.086

The responsibilities of the Department of Health and Social Services include the duty to:

• Identify family support services that will assist the parent or guardian in remedying the conduct or conditions in the home that 

made the child a child in need of aid
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• Actively offer the parent or guardian, and refer the parent or guardian to, those services

• Document its actions

When Reasonable Efforts Are Required

Citation: Alaska Stat. § 47.10.086

The department shall make timely efforts to provide family support services to the child and parents that are designed to prevent 

out-of-home placement of the child or to enable the safe return of the child to the family home, when appropriate.

If the child cannot be returned home safely, the department shall make reasonable efforts to place the child in a timely manner in 

accordance with the permanency plan and complete whatever steps are necessary to finalize the permanent placement of the child.

When Reasonable Efforts Are NOT Required 

Citation: Alaska Stat. § 47.10.086

The court may determine that reasonable efforts are not required if the court has found by clear and convincing evidence that:

• The parent has subjected the child to circumstances that pose a substantial risk of harm, including abandonment, sexual 

abuse, torture, chronic mental injury, or chronic physical harm.

• The parent has committed or attempted to commit murder of the other parent of the child or has committed felony assault 

that results in serious physical injury.

• The parent has failed, during the preceding 12 months, to participate in family support services.

• The department cannot identify and locate the parent.

• The parent has a mental illness and will be unable to care for the child in the foreseeable future.

• The parent has a previous conviction for a crime involving a child and, after the conviction, the child was returned to the parent 

and later removed because of an additional substantiated report of physical or sexual abuse.

• A child has suffered substantial physical harm as the result of abuse or neglect by the parent or by a person known to the 

parent, and the parent knew or reasonably should have known that the person was abusing the child.

• Rights to another child have been previously terminated, and conditions in the home have not been remedied. 

• The parent is incarcerated for a substantial period of time during the child’s minority.

The department is not required to make reasonable efforts to return the child to his or her family home if the department took 

emergency custody of an infant under § 47.10.142 after the infant was abandoned safely within the meaning of § 47.10.013(c). 

American Samoa

What Are Reasonable Efforts?

This issue is not addressed in the statutes reviewed. 

When Reasonable Efforts Are Required

This issue is not addressed in the statutes reviewed. 

When Reasonable Efforts Are NOT Required

This issue is not addressed in the statutes reviewed. 

Arizona

What Are Reasonable Efforts? 

Citation: Rev. Stat. §§ 8-801; 8-891

‘In-home intervention’ means a program of services provided pursuant to § 8-891 while the child is still in the custody of the parent, 

guardian, or custodian.

After a dependency petition is filed, the court may order in-home intervention if all of the following are true:

• The child has not been removed from the home.

• In-home intervention appears likely to resolve the risk issues described below.

• The parent, guardian, or custodian agrees to a case plan and participation in services.
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• One of the following conditions exists:

» The child is at risk of harm due to the inability or unwillingness of the parent, guardian, or custodian to provide food, 

clothing, shelter, or medical care.

» The parent, guardian, or custodian is unable to provide proper care, control, and supervision of the child.

The in-home intervention order may include a training or treatment plan for the parent, guardian, or custodian and the child. The 

in-home intervention shall include a specific time for completion that shall not exceed 1 year without review and approval by the 

court. 

The term ‘protective services’ is defined as a specialized child welfare program that is administered by the department to investigate 

allegations and seek to prevent, intervene in, and treat abuse and neglect to promote the well-being of the child in a permanent 

home and to coordinate services to strengthen the family.

When Reasonable Efforts Are Required

Citation: Rev. Stat. § 8-846

If the child has been removed from the home, the court shall order the Department of Child Safety to make reasonable efforts to 

provide services to the child and the child’s family.

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. § 8-846

Reunification services are not required when one or more of the following aggravating circumstances exist:

• A diligent search has failed to locate the parent, or the parent has expressed no interest in reunifying the child, for at least 

3 months.

• The parent is suffering from a mental illness or deficiency of such magnitude that the parent is incapable of benefitting from 

reunification services, or that, even with the provision of services, the parent is unlikely to be capable of adequately caring for 

the child within 12 months.

• The child previously has been removed from the home due to physical or sexual abuse, and, after the child was returned to the 

parent, the child was removed again within 18 months due to additional abuse.

• The parent committed a dangerous crime against a child, caused a child to suffer serious physical or emotional injury, or knew 

or reasonably should have known that another person committed a dangerous crime against children or caused a child to 

suffer serious physical or emotional injury.

• The parent’s rights to another child have been terminated, the parent has not successfully addressed the issues that led to the 

termination, and the parent is unable to fulfill parental responsibilities.

• After a finding that a child is dependent, all of the following are true:

» A child has been removed from the parent on at least two previous occasions.

» Reunification services were offered or provided to the parent.

» The parent is unable to fulfill parental responsibilities.

• The parent has been convicted of a dangerous crime against a child; murder or manslaughter of a child; sexual abuse, sexual 

assault, or molestation of a child; sexual conduct with a minor; commercial sexual exploitation of a minor; or luring a minor for 

sexual exploitation.

• The parent of a child has been convicted of aiding or abetting, attempting, conspiring, or soliciting to commit any of the 

crimes listed above.

Arkansas

What Are Reasonable Efforts? 

Citation: Ann. Code § 9-27-303

‘Reasonable efforts’ are measures taken to preserve the family and can include reasonable care and diligence on the part of the 

Department of Human Services or agency to utilize all available services related to meeting the needs of the juvenile and the family.

Reasonable efforts may include the provision of ‘family services,’ which are relevant services provided to a juvenile or his or her 

family, including, but not limited to:

• Child care 

• Homemaker services

• Crisis counseling

• Cash assistance
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• Transportation

• Family therapy

• Physical, psychiatric, or psychological evaluation

• Counseling or treatment

• Postadoptive services

Family services are provided in order to:

• Prevent a juvenile from being removed from a parent, guardian, or custodian

• Reunite the juvenile with the parent, guardian, or custodian from whom the juvenile has been removed

• Implement a permanent plan of adoption or guardianship for a juvenile in a dependency-neglect case

• Rehabilitate a juvenile in a delinquency or family in need of services case

When Reasonable Efforts Are Required 

Citation: Ann. Code § 9-27-303

Reasonable efforts shall be made:

• Before the placement of a child in foster care to prevent the need for removing the child from the child’s home

• To reunify a family after a child has been placed out of the home to make it possible for the child to return home safely

• To obtain permanency for a child who has been in placement more than 12 months, or 15 of the previous 22 months

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 9-27-303

Reasonable efforts to reunite a child with his or her parent or parents shall not be required in all cases. Reunification shall not be 

required if a court finds by clear and convincing evidence that the parent has:

• Subjected the child to aggravated circumstances, which may include: 

» A child has been abandoned, chronically abused, subjected to extreme or repeated cruelty, or sexually abused, or a 

determination has been made by a judge that there is little likelihood that services to the family will result in successful 

reunification.

» A child has been removed from the custody of the parent or guardian and placed in foster care or in the custody of another 

person three or more times in the past 15 months.

» A child or a sibling has been neglected or abused such that the abuse or neglect could endanger the life of the child.

• Committed or attempted to commit murder or manslaughter of any child

• Committed felony battery to any child that results in serious bodily injury

• Had parental rights terminated to a sibling of the child

• Abandoned an infant 

• Registered with a sex offender registry under the Adam Walsh Child Protection and Safety Act of 2006

California

What Are Reasonable Efforts? 

Citation: Welf. & Inst. Code § 361.5

The term ‘reunification services’ includes:

• Child welfare services

• Court-ordered counseling and other treatment services for the reunification of the child with the child’s family

When Reasonable Efforts Are Required 

Citation: Welf. & Inst. Code § 361.5

Family reunification services are required when a child is removed from a parent’s or guardian’s custody and shall be provided as 

follows:

• For a child age 3 or older, services may not be offered for longer than a period of 12 months from the date the child entered 

foster care.

• For a child under age 3, services may not be offered for longer than period of 6 months from the date the child entered foster 

care.
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For the purpose of placing and maintaining a sibling group together in a permanent home if reunification efforts fail, for a child in a 

sibling group that was removed from the physical custody of his or her parent or guardian and in which one member of that group 

was under age 3 on the date of initial removal, court-ordered services to some or all of the sibling group may be limited to a period 

of 6 months from the date the child entered foster care. For the purposes of this paragraph, a sibling group is two or more children 

who are related to each other as full or half siblings.

When Reasonable Efforts Are NOT Required 

Citation: Welf. & Inst. Code § 361.5

Reunification services need not be provided when the court finds by clear and convincing evidence any of the following:

• The whereabouts of the parent are unknown.

• The parent has a mental disability that makes him or her incapable of utilizing services.

• There is a prior adjudication of physical or sexual abuse of a child, and after the child was returned home, the child has been 

removed due to additional physical or sexual abuse.

• The parent caused the death of another child through abuse or neglect.

• A child younger than age 5 has suffered severe physical abuse that was inflicted by the parent, as defined in § 300(e).

• The parent has inflicted severe physical or sexual abuse on the child or a sibling, and the court finds that it would not benefit 

the child to pursue reunification with the offending parent.

• The parent is not receiving reunification services for a sibling of the child.

• The child was conceived as a result of a sexual offense.

• The parent has willfully abandoned the child.

• The court ordered termination of reunification services for any siblings of the child because the parent failed to reunify with 

the sibling, and that parent has not subsequently made a reasonable effort to treat the problems that led to removal of the 

sibling from the parent.

• The parent’s rights to another child have been terminated, and conditions that led to the termination have not been remedied.

• The parent has been convicted of a violent felony.

• The parent has a history of chronic use of drugs or alcohol and refused to comply with a treatment program.

• The parent has indicated a lack of interest in reunification services.

• The parent has on one or more occasions abducted the child or a sibling from his or her placement.

Colorado

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 19-1-103(89), (10)

The term ‘reasonable efforts’ means the exercise of diligence and care for children who are in out-of-home placement or are at 

imminent risk of out-of-home placement. In determining whether it is appropriate to provide, purchase, or develop the supportive 

and rehabilitative services that are required to prevent unnecessary placement of a child outside of a child’s home or to foster the 

safe reunification of a child with a child’s family, or whether it is appropriate to find and finalize an alternative permanent plan for a 

child. In making reasonable efforts, the child’s health and safety shall be the paramount concern. Services provided by a county or 

city agency in accordance with § 19-3-208 are deemed to meet the reasonable effort standard described in this subsection.

The term ‘appropriate treatment plan,’ as used in § 19-3-508(1)(e), means a treatment plan approved by the court that is reasonably 

calculated to render the particular respondent fit to provide adequate parenting to the child within a reasonable time and that 

relates to the child’s needs.

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 19-1-115(6)

Reasonable efforts must be made:

• To prevent or eliminate the need to remove the child from the home

• To reunite the child and the family if legal custody has been awarded to the Department of Human Services
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When Reasonable Efforts Are NOT Required

Citation: Rev. Stat. § 19-1-115(7)

Reasonable efforts are not required to prevent the child’s removal from the home or to reunify the child and the family in the 

following circumstances:

• The court finds that the parent has subjected the child to aggravated circumstances to such an extent that grounds exist for 

termination of the parent’s parental rights, as described in § 19-3-604(1).

• The parental rights of the parent with respect to a sibling of the child have been involuntarily terminated, unless the prior 

sibling termination resulted from a parent delivering a child to a firefighter or a hospital staff member pursuant to § 19-3-304.5.

• The court finds that the parent has been convicted of murder or voluntary manslaughter of another child of the parent; aiding, 

abetting, or attempting to commit such crimes; or a felony assault that resulted in serious bodily injury to the child or to 

another child of the parent.

Connecticut

What Are Reasonable Efforts?

Citation: Gen. Stat. § 46b-129

The term ‘reasonable efforts’ refers to the services to be provided to the parents and the steps the parents may take to address the 

problems that prevent the child from safely reuniting with the parents.

When Reasonable Efforts Are Required

Citation: Gen. Stat. §§ 46B-129; 17a-111b

The Department of Children and Families must make reasonable efforts to keep the child or youth with his or her parents prior to the 

issuance of an order to remove the child from the home. If the child is removed from the home, reasonable efforts must be made to 

achieve the goals of the permanency plan.

The Commissioner of Children and Families shall make reasonable efforts to reunify a parent with a child unless the court (1) 

determines that such efforts are not required pursuant to § 17a-111b(b) or § 17a-112(j), or (2) has approved a permanency plan other 

than reunification pursuant to § 46b-129(k).

When Reasonable Efforts Are NOT Required

Citation: Gen. Stat. § 17a-111b

The commissioner or any other party may, at any time, file a motion with the court for a determination that reasonable efforts to 

reunify the parent with the child are not required. The court may determine that such efforts are not required if the court finds upon 

clear and convincing evidence that:

• The parent has subjected the child to the following aggravated circumstances:

» The parent has abandoned the child.

» The parent has inflicted or knowingly permitted another person to inflict sexual molestation or exploitation or severe 

physical abuse on the child or engaged in a pattern of abuse of the child.

• The parent has killed, through deliberate, nonaccidental act, another child of the parent or a sibling of the child; or has 

requested, commanded, importuned, attempted, conspired, or solicited to commit or knowingly permitted another person to 

commit the killing of the child, another child of the parent, or a sibling of the child.

• The parent has committed or knowingly permitted another person to commit an assault, through deliberate, nonaccidental 

act, that resulted in serious bodily injury of the child, another child of the parent, or a sibling of the child.

• The parental rights of the parent to a sibling have been terminated within 3 years of the filing of a petition pursuant to this 

section, provided the commissioner has made reasonable efforts to reunify the parent with the child for at least 90 days.

• The parent was convicted of sexual assault, except a conviction of a violation of § 53a-71 or 53a-73a resulting in the conception 

of the child.

• The child was placed in the care and control of the commissioner pursuant to the provisions of §§ 17a-57 to 17a-61, inclusive.
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Delaware

What Are Reasonable Efforts? 

Citation: Ann. Code Tit. 29, § 9003

The Division of Family Services will provide family preservation services. 

The division must prepare and maintain a written case plan for each child under its supervision or custody that shall include, but not 

be limited to, a description of the child’s problems, the care and treatment of the child, and any other services to be provided to the 

child and the child’s family.

When Reasonable Efforts Are Required 

Citation: Ann. Code Tit. 29, § 9003

The division will provide family preservation services to those families whose children are at imminent risk of out-of-home placement 

when it is determined that out-of-home placement can be avoided. However, the division’s highest priority in cases of abuse and 

neglect where an investigation is required shall be the health and safety of the child, and nothing herein will prevent the division 

from removing a child from the child’s home when it has determined that the child’s safety and well-being may be jeopardized by 

remaining in the family home.

Each case plan must be designed to achieve any placement of the child outside of the child’s home in the least restrictive setting 

available and in close proximity to the child’s home, consistent with the best interests and special needs of the child.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code Tit. 13, § 1103

The division is not required to perform, but is not prohibited from performing, reunification and related services, as outlined in title 

29, § 9003, when the grounds for termination of parental rights are those stated below: 

• The child has been abandoned.

• The parent has been found by a court of competent jurisdiction to have:

» Committed a felony-level offense against a child 

» Aided or abetted, attempted, conspired, or solicited to commit an offense listed above 

» Committed or attempted to commit the offense of Dealing in Children

» Committed the felony-level offense of endangering the welfare of a child

• The parent’s parental rights over a sibling of the child have been involuntarily terminated in a prior proceeding.

• The parent has subjected the child to torture, chronic abuse, sexual abuse, and/or life-threatening abuse.

• A child has suffered unexplained serious physical injury, death, or near death under circumstances that would indicate that the 

injuries resulted from the intentional or reckless conduct or willful neglect of the parent.

District of Columbia

What Are Reasonable Efforts? 

Citation: Ann. Code § 4-1301.02

Family preservation services are services for children and families that are at risk of abuse or neglect, or are in crisis, and include: 

• Services designed to help children return to families from which they have been removed, or be placed for adoption, 

when safe and appropriate, or with a legal guardian, or, if adoption or legal guardianship is determined not to be safe and 

appropriate for the child, in another permanent living arrangement

• Replacement prevention services

• Services that provide follow-up care to families to whom a child has returned after commitment

• Respite care services 

• Services designed to improve parenting skills and abilities 

Family support services promote the safety and well-being of children and families, are community-based, and are designed to:

• Increase family strength and stability

• Increase parent confidence and competence 

• Afford children safe, stable, and supportive family environments 

• Enhance child development
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Time-limited family reunification services are services and activities provided to a committed child and to the child’s parent, 

guardian, or custodian in order to facilitate the safe, appropriate, and timely reunification of the child during the 15 months following 

the child’s entry into foster care. Time-limited family reunification services include:

• Individual, group, and family counseling

• Inpatient, residential, or outpatient substance abuse treatment services

• Mental health services

• Assistance to address domestic violence

• Services designed to provide temporary child care and therapeutic services for families

• Transportation to or from any of the services and activities described above

When Reasonable Efforts Are Required 

Citation: Ann. Code § 4-1301.09a

The Child and Family Services Agency shall make reasonable efforts to preserve and reunify the family:

• Prior to the removal of the child from the home to prevent or eliminate the need for removing the child

• To make it possible for the child to return home safely

• To place the child in accordance with that plan in order to finalize a permanent placement if return home is inconsistent with 

the child’s permanency plan 

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 4-1301.09a

Reasonable efforts to reunify are not required if the parent:

• Subjected the child, a sibling, or other child to cruelty, abandonment, torture, chronic abuse, or sexual abuse

• Committed, aided, abetted, solicited, or attempted to commit murder or voluntary manslaughter of a sibling or other child

• Committed a felony assault against the child, a sibling, or other child

• Had his or her parental rights terminated involuntarily with respect to a sibling

• Is required to register with a sex offender registry under 42 U.S.C. § 16913(a)

Florida

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 39.521(1)(f)

The term ‘reasonable efforts’ means the exercise of reasonable diligence and care by the Department of Children and Families to 

provide the services ordered by the court or delineated in the case plan. 

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 39.521(1)(f)

If the court finds that the prevention or reunification efforts by the department will allow the child to remain safely at home or be 

returned to the home safely, the court shall allow the child to remain in or return to the home after making a specific finding of 

fact that the reasons for removal have been remedied to the extent that the child’s safety, well-being, and physical, mental, and 

emotional health will not be endangered.

If the court places the child in an out-of-home placement, the disposition order must include a written determination that the 

child cannot remain at home safely with reunification or family preservation services and that removal of the child is necessary to 

protect the child. If the child is removed before the disposition hearing, the order must also include a written determination as to 

whether, after removal, the department made a reasonable effort to reunify the parent and child. The department has the burden of 

demonstrating that it made reasonable efforts.

The court shall determine whether reasonable efforts have been made by reviewing:

• Whether or not prevention or reunification services were indicated

• A written description of what appropriate and available prevention and reunification efforts were made

• Why further efforts could or could not have prevented or shortened the separation of the parent and child

A reasonable effort has been made if the appraisal of the home situation indicates the severity of conditions is such that reunification 

efforts were inappropriate.
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When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. §§ 39.521(1)(f); 39.806(1)

Reasonable efforts are not required when:

• The parent has breached the case plan.

• The parent has abandoned the child.

• The parent is incarcerated, the term of incarceration constitutes a significant portion of the child’s minority, and continuing the 

parental relationship with that parent would be harmful to the child.

• The parent’s conduct threatens the child’s life; safety; well-being; or physical, mental, or emotional health.

• The parent engaged in egregious conduct or had the opportunity to prevent and knowingly failed to prevent egregious 

conduct that threatened the child’s life; safety; or physical, mental, or emotional health.

• The parent has subjected the child or another child to aggravated child abuse, sexual battery, sexual abuse, or chronic abuse.

• The parent has committed the murder, manslaughter, aiding or abetting the murder, or conspiracy or solicitation to murder the 

other parent or another child, or a felony battery that resulted in serious bodily injury to the child or to another child.

• The parental rights of the parent to a sibling of the child have been terminated involuntarily.

• The parent has a history of extensive, abusive, and chronic use of alcohol or a controlled substance that makes him or her 

incapable of caring for the child and has refused or failed to complete available treatment.

• A newborn child had a positive test that indicated the presence of alcohol or a controlled substance, the presence of which was 

not the result of medical treatment to the mother or the newborn, and the mother is the birth mother of at least one other child 

who was found dependent due to exposure to a controlled substance or alcohol.

• On three or more occasions, the child or another child of the parent has been placed in out-of-home care, and the conditions 

that led to the child’s out-of-home placement were caused by the parent.

• The child was conceived as a result of an act of sexual battery.

Georgia

What Are Reasonable Efforts? 

Citation: Ann. Code § 15-11-2

‘Reasonable efforts’ means due diligence and the provision of appropriate services. 

When Reasonable Efforts Are Required 

Citation: Ann. Code §§ 15-11-202; 15-11-203

Except as provided below, reasonable efforts shall be made to preserve or reunify families:

• Prior to the placement of an alleged dependent child in to the custody of the Division of Family and Children Services (DFCS) to 

prevent the need for removing him or her from his or her home

• To eliminate the need for removal and make it possible for a child alleged to be or adjudicated as a dependent child to return 

safely to his or her home at the earliest possible time

In determining the type of reasonable efforts to be made to a child alleged to be or adjudicated as a dependent child and in making 

such reasonable efforts, such child’s health and safety shall be the paramount concern.

If the court determines that reasonable efforts to reunify a child with his or her parents have been made, or DFCS has submitted a 

written report to the court that does not contain a plan for reunification services, then reasonable efforts shall be made to place a child 

in a timely manner in accordance with the permanency plan and to complete whatever steps are necessary to finalize the permanent 

placement of such child.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 15-11-203

The court may direct that reasonable efforts to eliminate the need for placement of an alleged dependent child shall not be required 

or shall cease if the court determines that the parent:

• Has subjected his or her child to aggravated circumstances

• Has been convicted of the murder or voluntary manslaughter of another child of the parent

• Has been convicted of aiding or abetting, attempting, conspiring, or soliciting to commit murder or voluntary manslaughter of 

another child of the parent

• Has been convicted of committing a felony assault that results in serious bodily injury to the child or another child of the parent
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• Has been convicted of rape, sodomy, aggravated sodomy, child molestation, aggravated child molestation, incest, sexual 

battery, or aggravated sexual battery of the alleged dependent child or another child of the parent

• Is required to register as a sex offender and that preservation of a parent-child relationship is not in the child’s best interests

• Has had his or her rights to a sibling of the child terminated involuntarily and the circumstances leading to the termination of 

parental rights to that sibling have not been resolved

Guam

What Are Reasonable Efforts? 

Citation: Ann. Code Tit. 19, § 13304

A service plan is a specific, written plan prepared by Child Protective Services and presented to members of the child’s family. The 

service plan should also include, but not necessarily be limited to, the specific services or treatment that the parties will be provided 

and the specific actions the parties must take or specific responsibilities that the parties must assume.

When Reasonable Efforts Are Required 

Citation: Ann. Code Tit. 19, § 13304

The service plan should set forth: 

• The steps that will be necessary to facilitate the return of the child to a safe family home if the proposed placement of the 

child is in foster care or in alternate placement outside of the child’s home

• The steps that will be necessary for the child to remain in a safe family home with the assistance of a service plan, if the 

proposed placement of the child is in a family home under Child Protective Services’ supervision

• The steps that will be necessary to make the family home a safe family home and to terminate intervention of Child Protective 

Services into the family and eliminate, if possible, the necessity for the filing of a petition with the court under this chapter

When Reasonable Efforts Are NOT Required

This issue is not addressed in the statutes reviewed. 

Hawaii

What Are Reasonable Efforts? 

Citation: Rev. Stat. §§ 587A-2; 587A-27

The service plan shall be carefully formulated with the family in a timely manner. Every reasonable opportunity should be provided 

to help the child’s legal custodian to succeed in remedying the problems that put the child at substantial risk of being harmed in 

the family home. Each appropriate resource, public and private, family and friend, should be considered and used to maximize the 

legal custodian’s potential for providing a safe family home for the child. Full and careful consideration shall be given to the religious, 

cultural, and ethnic values of the child’s legal custodian when service plans are being discussed and formulated. 

The service plan shall provide the specific steps necessary to facilitate the return of the child to a safe family home, if the proposed 

placement of the child is in foster care under foster custody. These specific steps shall include treatment and services that will be 

provided, actions completed, specific measurable and behavioral changes that must be achieved, and responsibilities assumed. 

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 587A-2

The service plan shall effectuate the child’s remaining in the family home, when the family home can be immediately made safe with 

services, or the child’s returning to a safe family home. 

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. §§ 587A-28; 587A-4 

The court need not order a service plan if the court finds that aggravated circumstances are present. The term ‘aggravated 

circumstances’ means that:

• The parent has murdered or has solicited, aided, abetted, attempted, or conspired to commit the murder or voluntary 

manslaughter of another child of the parent. 

• The parent has committed a felony assault that results in serious bodily injury to the child or another child of the parent.

• The parent’s rights regarding a sibling of the child have been judicially terminated.

• The parent has tortured the child.
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• The child is an abandoned infant.

• The parent has committed sexual abuse against another child of the parent.

• The parent is required to register with a sex offender registry under the Adam Walsh Child Protection and Safety Act of 2006 

(42 U.S.C. § 16913(a)).

Idaho

What Are Reasonable Efforts? 

Citation: Idaho Code § 16-1621(1), (3)

The Department of Health and Welfare shall prepare a written case plan in every case in which the child is determined to be within 

the jurisdiction of the court, including cases in which the parent(s) is incarcerated. 

If the child is placed in the legal custody of the department, the case plan shall set forth reasonable efforts that will be made to make 

it possible for the child to return home. The case plan also shall:

• Identify the services to be provided to the child, including services to identify and meet any special educational, emotional, 

physical, or developmental needs the child may have; to assist the child in adjusting to the placement; or to ensure the 

stability of the placement

• Address options for maintaining the child’s connection to the community, including individuals with a significant relationship 

to the child, and organizations or community activities with which the child has a significant connection

• Include a goal of reunification and a plan for achieving that goal

The reunification plan shall identify all issues that need to be addressed before the child can safely be returned home without 

department supervision. The reunification plan shall specifically identify the tasks to be completed by the department, each 

parent, or others to address each issue, including services to be made available by the department to the parents and in which the 

parents are required to participate, and deadlines for completion of each task. The case plan shall state with specificity the role of 

the department toward each parent. When appropriate, the reunification plan should identify terms for visitation, supervision of 

visitation, and child support.

When Reasonable Efforts Are Required 

Citation: Idaho Code § 16-1619(6)

If the court vests legal custody in the department or other authorized agency, the court shall make detailed written findings based 

on facts in the record as to whether the department made reasonable efforts to prevent the placement of the child in foster care, 

including findings, when appropriate, that:

• Reasonable efforts were made but were not successful in eliminating the need for foster care placement of the child.

• The department made reasonable efforts to prevent removal but was not able to safely provide preventive services.

• Reasonable efforts to temporarily place the child with related persons were made but were not successful.

• Reasonable efforts were not required as the parent had subjected the child to aggravated circumstances.

When Reasonable Efforts Are NOT Required 

Citation: Idaho Code §§ 16-1619(6)(d); 16-1602(5)

Reasonable efforts are not required if the parent has subjected the child to aggravated circumstances as determined by the court. 

‘Aggravated circumstances’ includes, but is not limited to:

• Circumstances in which the parent has engaged in any of the following:

» Abandonment, chronic abuse, or chronic neglect of the child

○ Chronic neglect or chronic abuse of a child shall consist of abuse or neglect that is so extreme or repetitious as to 

indicate that return of the child to the home would result in unacceptable risk to the health and welfare of the child.

» Sexual abuse against a child of the parent, which includes any conduct described in §§ 18-1506, 18-1506A, 18-1507, 18-1508, 

18-1508A, 18-6101, 18-6108, or 18-6608

» Torture of a child; any conduct described in the code sections listed in § 18-8303(1) (including ritualized abuse of a child, 

lewd conduct, murder committed in the perpetration of rape, kidnapping committed for the purpose of rape, committing 

an infamous crime against nature, committing any lewd and lascivious act upon any child under age 16 for purposes of 

sexual gratification or arousal, rape, forcible sexual penetration by use of a foreign object, or sex trafficking); battery or 

an injury to a child that results in serious or great bodily injury to a child; voluntary manslaughter of a child; or aiding or 

abetting such voluntary manslaughter, soliciting such voluntary manslaughter, or attempting or conspiring to commit such 

voluntary manslaughter
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• The parent has committed murder, aided or abetted a murder, solicited a murder, or attempted or conspired to commit 

murder.

• The parental rights of the parent to another child have been terminated involuntarily.

Illinois

What Are Reasonable Efforts? 

Citation: Cons. Stat. Ch. 325, § 5/8.2

The term ‘family preservation services’ refers to all services to help families, including adoptive and extended families.

Appropriate family preservation services shall be included in the service plan if the Department of Children and Family Services has 

determined that those services will ensure the child’s health and safety, are in the child’s best interests, and will not place the child in 

imminent risk of harm. Such plans may include, but are not limited to:

• Case management services

• Homemakers, including emergency caretakers, housekeepers, and chore services 

• Counseling, including individual therapy, infant stimulation therapy, family therapy, group therapy, self-help groups, drug and 

alcohol abuse counseling, vocational counseling, and postadoption services

• Parent education

• Day care, including protective day care and day care to meet educational, prevocational, or vocational needs

• Emergency assistance and advocacy assessments, including coordinated services to secure emergency cash, food, and 

housing

• Respite care

• In-home health care

• Transportation to obtain any of the above services

• Medical assistance

When Reasonable Efforts Are Required 

Citation: Cons. Stat. Ch. 20, § 505/5

The department shall offer family preservation services to help families, including adoptive and extended families. Such services 

shall be offered:

• To prevent the placement of children in substitute care when the children can be cared for at home or in the custody of the 

person responsible for the children’s welfare

• To reunite children with their families

• To maintain an adoptive placement

Family preservation services shall only be offered when doing so will not endanger the children’s health or safety. The child and his 

or her family shall be eligible for services as soon as the report of suspected child abuse or neglect is determined to be indicated. 

The department may also provide services to any child or family when the report of suspected abuse or neglect is determined to 

be unfounded if the conditions in the child’s or family’s home are reasonably likely to subject the child or family to future reports of 

suspected child abuse or neglect. Acceptance of such services shall be voluntary.

When a child is placed in foster care, the department shall ensure and document that reasonable efforts were made to prevent or 

eliminate the need to remove the child from the child’s home. The department must make reasonable efforts to reunify the family 

when temporary placement of the child occurs unless otherwise required. 

When Reasonable Efforts Are NOT Required 

Citation: Cons. Stat. Ch. 20, § 505/5; Ch. 705, § 405/2-13.1

When the department believes that further reunification services would be ineffective, it may request a finding from the court that 

reasonable efforts are no longer appropriate. The court shall grant this motion with respect to a parent of the minor if the court finds 

after a hearing that the parent has:

• Had his or her parental rights to another child involuntarily terminated

• Been convicted of: 

» First degree or second degree murder of another child of the parent 

» Attempt, conspiracy, or solicitation to commit first degree or second degree murder of another child of the parent
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» Aggravated battery, aggravated battery of a child, or felony domestic battery, any of which has resulted in serious bodily 

injury to the minor or another child of the parent

» An offense in any other State substantially similar to any of the above offenses

The department is not required to provide further reunification services after such a finding. 

Indiana

What Are Reasonable Efforts?

Citation: Ann. Code § 31-34-21-5.5

The term ‘reasonable efforts’ refers to measures taken to provide services to preserve and reunify families. 

When Reasonable Efforts Are Required

Citation: Ann. Code § 31-34-21-5.5

The Department of Child Services shall make reasonable efforts to preserve and reunify families as follows:

• If the child has not been removed from the home, to prevent or eliminate the need for removing the child

• If the child has been removed from the home, to make it possible for the child to return safely home as soon as possible

When Reasonable Efforts Are NOT Required

Citation: Ann. Code § 31-34-21-5.6

Reasonable efforts to reunite a child with his or her family or to preserve a family are not required when the court finds any of the 

following:

• A parent has been convicted of causing a suicide, involuntary manslaughter, rape, criminal deviate conduct, child molesting, 

or exploitation of a victim who is the parent’s child or the child’s other parent.

• A parent has been convicted of murder or voluntary manslaughter of a victim who is the parent’s child or the child’s other 

parent.

• A parent has been convicted of attempting, aiding, or conspiring to commit any of the above crimes.

• A parent has been convicted of battery, aggravated battery, criminal recklessness, or neglect against a child.

• The parental rights of a parent with respect to a sibling have been involuntarily terminated.

• The child is an abandoned infant.

Iowa

What Are Reasonable Efforts?

Citation: Ann. Stat. § 232.102

The term ‘reasonable efforts’ refers to efforts made to preserve and unify a family.

Reasonable efforts may include, but are not limited to, family-centered services if the child’s safety in the home can be maintained 

during the time the services are provided.

The term ‘family-centered services’ means services and other support intended to maintain a child safely with the child’s family 

or with a relative; to return a child, safely and in a timely manner, to the home of the child’s parent or relative; or to promote the 

achievement of concurrent planning goals by identifying and helping the child secure placement for adoption, with a guardian, or 

with other alternative permanent family connections. Family-centered services are adapted to the individual needs of a family in 

regard to the specific services and other support provided to the child’s family and the intensity and duration of service delivery. 

Family-centered services are intended to preserve a child’s connections to the child’s neighborhood, community, and family and to 

improve the overall capacity of the child’s family to provide for the needs of the children in the family. 

When Reasonable Efforts Are Required

Citation: Ann. Stat. § 232.102

Reasonable efforts are required:

• Prior to out-of-home placement of a child in foster care to eliminate the need for removal of the child

• To make it possible for the child to return safely to the family’s home

If returning the child to the family’s home is not appropriate or possible, reasonable efforts shall include the efforts made in a timely 

manner to finalize a permanency plan for the child. 
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When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 232.102

If the court determines by clear and convincing evidence that aggravated circumstances exist, the court may waive the requirement for 

making reasonable efforts. Aggravated circumstances include: 

• The parent has abandoned the child.

• The court finds the child in need of assistance based on a finding of physical or sexual abuse or neglect.

• The parent’s parental rights to another child have been terminated and there is clear and convincing evidence that services 

likely will not, within a reasonable time, correct the conditions that led to the child’s removal from the home.

• The parent has been convicted of murder or voluntary manslaughter of another child or the attempt to commit either crime.

• The parent has been convicted of a felony assault that resulted in serious bodily injury to the child or another child of the parent.

Kansas

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 38-2255

The court may place the child in the custody of either parent subject to terms and conditions that the court prescribes to assure the 

proper care and protection of the child that includes, but are not limited to:

• Supervision of the child and the parent by a court services officer

• Participation by the child and the parent in available programs operated by an appropriate individual or agency

• Any special treatment or care the child needs for his or her physical, mental, or emotional health and safety

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 38-2255

The court shall not enter an order removing a child from the custody of a parent pursuant to this section unless the court first finds 

probable cause that:

• The child is likely to sustain harm if not immediately removed from the home.

• Allowing the child to remain in home is contrary to his or her welfare.

• Immediate placement of the child is in his or her best interests, and reasonable efforts have been made to maintain the family 

unit and prevent the unnecessary removal of the child from the child’s home.

• An emergency exists that threatens the safety of the child.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 38-2255

If custody of the child has been awarded to a person other than a parent, a permanency plan shall be prepared. If a permanency plan 

is provided at the dispositional hearing, the court may determine whether reintegration is a viable alternative. In determining whether 

reintegration is a viable alternative, the court shall consider whether:

• The parent has been found by a court to have committed one of the following crimes or to have aided and abetted, attempted, 

conspired, or solicited the commission of one of these crimes:

» First- or second-degree murder

» Capital murder

» Voluntary manslaughter

» Felony battery that resulted in bodily injury

• The parent has subjected the child or another child to aggravated circumstances.

• The parent has previously been found to be an unfit parent.

• The child has been in extended out-of-home placement.

• The parents have failed to work diligently toward reintegration. 

• The secretary has provided the family with services necessary for the safe return of the child to the home.

• It is reasonable to expect reintegration to occur within a timeframe consistent with the child’s developmental needs.
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Kentucky

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 620.020

The term ‘reasonable efforts’ means the exercise of ordinary diligence and care by the department to utilize all preventive and 

reunification services that are available to the community and necessary to enable to child to live safely at home. 

When Reasonable Efforts Are Required 

Citation: Rev. Stat. §§ 620.020; 620.130

Reunification services are remedial services that are designed to: 

• Strengthen the family unit

• Secure reunification of the family and child, where appropriate, as quickly as practicable

• Prevent the future removal of the child from the family

When the court is petitioned to remove or continue the removal of a child from the custody of his parent or other person exercising 

custodial control or supervision, the court first shall consider whether the child may be reasonably protected against the alleged 

dependency, neglect, or abuse by alternatives less restrictive than removal. Such alternatives may include, but shall not be limited 

to, the provision of medical, educational, psychiatric, psychological, social work, counseling, day care, or homemaking services 

with monitoring wherever necessary by the Cabinet for Health and Family Services or other appropriate agency. When the court 

specifically finds that such alternatives are adequate to reasonably protect the child against the alleged dependency, neglect, or 

abuse, the court shall not order the removal or continued removal of the child.

If the court orders the removal or continues the removal of the child, services provided to the parent and the child shall be designed 

to promote the protection of the child and the return of the child safely to the child’s home as soon as possible. The cabinet shall 

develop a treatment plan for each child designed to meet the needs of the child.

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. §§ 610.127; 600.020

Reasonable efforts shall not be required if a court determines that: 

• The parent has subjected the child to aggravated circumstances, including any of the following:

» The parent has not had contact with the child for more than 90 days.

» The parent is incarcerated for at least 1 year, will be unavailable to care for the child, and there is no appropriate relative to 

care for the child.

» The parent has sexually abused the child and refused available treatment.

» The parent has engaged in abuse of the child that required removal two or more times in the last 2 years.

» The parent has caused the child serious physical injury.

• The parent has been convicted of having caused the death of another child of the parent.

• The parent has committed a felony assault that resulted in serious bodily injury to the child or another child of the parent.

• The parent had his or her parental rights to another child terminated involuntarily.

• The parent has engaged in a pattern of conduct due to alcohol or drug abuse that has rendered the parent incapable of 

caring for the immediate and ongoing needs of the child, and has refused or failed to complete a treatment plan.

• The parent has a mental illness or retardation that places the child at substantial risk of harm even if services were provided to 

the parent for 12 months.

• The parent has sexually abused the child or is required to register on a sex offender registry under 42 U.S.C. § 16913, the Adam 

Walsh Child Protection and Safety Act of 2006.

• Other circumstances make reasonable efforts inconsistent with the best interests of the child and the permanency plan for the 

child.
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Louisiana

What Are Reasonable Efforts? 

Citation: Ch. Code Art. 603(25)

The term ‘reasonable efforts’ means the exercise of ordinary diligence and care by department caseworkers and supervisors and 

shall assume the availability of a reasonable program of services to children and their families.

When Reasonable Efforts Are Required 

Citation: Ch. Code Art. 626; 684

The court shall determine whether the Department of Children and Family Services has made reasonable efforts to prevent or 

eliminate the need for removal of the child from his or her home and, after removal, to make it possible for the child to return home 

safely. 

The court may authorize, with the consent of the State, continued implementation of a safety plan prior to the adjudication if there 

are reasonable grounds to believe the child is in need of care and that the continued implementation of the safety plan is necessary 

for his or her safety and protection. The safety plan shall continue to set forth conditions as determined or agreed upon by the State 

as necessary for the protection of the child’s health and safety while remaining in the home.

When the child is to be removed from his or her parents’ custody, the court shall determine whether reasonable efforts have been 

made to prevent removal and what preventive or reunification efforts, or both, were made, and why further efforts could or could not 

have prevented or shortened the separation of the family.

When Reasonable Efforts Are NOT Required 

Citation: Ch. Code Art. 672.1

At any time in a child in need of care proceeding for a child who is in the custody of the department, the department may file a 

motion for a judicial determination that efforts to reunify the parent and child are not required. The department shall have the 

burden of demonstrating by clear and convincing evidence that reunification efforts are not required, considering the health and 

safety of the child and the child’s need for permanency.

Efforts to reunify the parent and child are not required if a court has determined that:

• The parent has subjected the child to egregious conduct or conditions, including any of the grounds for termination of 

parental rights pursuant to Article 1015.

• The parent has committed or attempted to commit murder or manslaughter of another child of the parent or any other child or 

has aided or abetted, attempted, conspired, or solicited to commit such a murder or manslaughter.

• The parent has committed a felony that resulted in serious bodily injury to the child, another child of the parent, or any other 

child.

• The parent’s parental rights to a sibling have been terminated involuntarily.

Maine

What Are Reasonable Efforts? 

Citation: Ann. Stat. Tit. 22, § 4041(1-A)

The Department of Health and Human Services shall develop a written rehabilitation plan that includes:

• Services that must be provided to address the problems in the family that present a risk of harm to the child

• Provisions to ensure the safety of the child while the parent engages in those services

• A means to measure the extent to which progress has been made

• Visitation that protects the child’s physical and emotional well-being

When Reasonable Efforts Are Required 

Citation: Ann. Stat. Tit. 22, § 4036-B

The department shall make reasonable efforts to:

• Prevent removal of the child from home, unless the court finds the presence of an aggravating factor 

• Rehabilitate and reunify the family, as provided in § 4041(1-A), unless the court has ordered that the department need not 

commence or may cease reunification 

• Finalize the permanency plan
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When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. Tit. 22, §§ 4041(2)(A-2); 4002(1-B)

The court may order that reunification efforts are not required if it finds one of the following:

• The existence of an aggravating factor

• That continuation of reunification efforts is inconsistent with the permanency plan for the child

An aggravating factor includes any of the following circumstances with regard to the parent: 

• The parent has subjected a child for whom the parent was responsible to rape, gross sexual misconduct, gross sexual assault, 

sexual abuse, incest, aggravated assault, kidnapping, promotion of prostitution, abandonment, torture, chronic abuse, or any 

other treatment that is heinous or abhorrent to society. 

• The parent refused for 6 months to comply with treatment required in a reunification plan with regard to the child.

• The parent has been convicted of any of the following crimes and the victim of the crime was a child for whom the parent was 

responsible or was a child who was a member of a household lived in or frequented by the parent:

» Murder, felony murder, or manslaughter

» Aiding, conspiring, or soliciting murder or manslaughter

» Felony assault that results in serious bodily injury

» Any comparable crime in another jurisdiction

• The parental rights of the parent to a sibling have been terminated involuntarily.

• The parent has abandoned the child.

Maryland

What Are Reasonable Efforts? 

Citation: Family Law § 5-525(c)

The Department of Human Resources shall provide time-limited family reunification services to a child placed in an out-of-home 

placement and to the parent or guardian of the child in order to facilitate the child’s safe and appropriate reunification in a timely 

manner.

When Reasonable Efforts Are Required 

Citation: Family Law § 5-525(e)

Reasonable efforts shall be provided to preserve or reunify a family:

• Prior to an out-of-home placement to prevent or eliminate the need for removing the child from home

• To make it possible for a child to return home safely

• To finalize a permanent placement for the child if continuation of reasonable efforts is determined to be inconsistent with the 

permanency plan

When Reasonable Efforts Are NOT Required 

Citation: Courts & Jud. Proc. § 3-812(b)

A local department may ask the court to find that reasonable efforts to reunify a child with the child’s parent are not required if the 

local department concludes that a parent:

• Has subjected the child to any of the following aggravated circumstances:

» The parent has engaged in or facilitated chronic or severe physical abuse, chronic and life-threatening neglect, sexual 

abuse, or torture of the child, a sibling of the child, or another child in the household.

» The parent knowingly failed to take appropriate steps to protect the child after a person in the household inflicted sexual 

abuse, severe physical abuse, life-threatening neglect, or torture on the child or another child in the household.

» The child, a sibling of the child, or another child in the household has suffered severe physical abuse or death resulting 

from abuse by the parent or another adult in the household, and all persons who could have inflicted the abuse or caused 

the death remain in the household.

» The parent has abandoned the child.

• Has been convicted, in any State or any court of the United States, of:

» A crime of violence against a minor offspring of the parent or guardian, the child, or another parent of the child

» Aiding or abetting, conspiring, or soliciting to commit a crime of violence

• Has involuntarily lost parental rights of a sibling of the child
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The term ‘crime of violence’ includes abduction, arson, kidnapping, manslaughter, mayhem, maiming, rape, robbery, carjacking, 

sexual offenses, use of a handgun in the commission of a felony or other crime of violence, first-degree child abuse, and assault. 

Massachusetts

What Are Reasonable Efforts? 

Citation: Ann. Laws Ch. 119, § 29C

The court shall determine the reasonable efforts to be made, consistent with the best interests of the child. 

When Reasonable Efforts Are Required 

Citation: Ann. Laws Ch. 119, § 29C

Reasonable efforts shall be made:

• Prior to placement to prevent or eliminate the need for removal from the home

• To make it possible for a child to return safely to his or her parent or guardian 

• To place the child, in a timely manner, in accordance with the permanency plan if reasonable efforts to reunify the child with 

his or her parent or guardian are inconsistent with the permanency plan

When Reasonable Efforts Are NOT Required 

Citation: Ann. Laws Ch. 119, § 29C

Reasonable efforts shall not be required if the court finds:

• The child has been abandoned.

• The parent’s rights to another child have been involuntarily terminated.

• The parent has been convicted of murder or voluntary manslaughter of another child of the parent or aiding or abetting in the 

commission of such crime.

• The parent has been convicted of a felony assault resulting in serious bodily injury of the child or another child of the parent.

• The parent has subjected the child to aggravated circumstances that may include murder of another parent of the child in the 

presence of the child, subjecting the child or other children in the home to sexual abuse or exploitation, or severe or repetitive 

conduct of a physically or emotionally abusive nature. 

Michigan

What Are Reasonable Efforts? 

Citation: Comp. Laws § 712A.18f

Reasonable efforts are measures taken to preserve and reunify the family and may include:

• Efforts to be made by the parents

• Efforts to be made by the agency

• A schedule of services to be provided, including in-home services

• A schedule of parenting time between the child and the parent, if appropriate

When Reasonable Efforts Are Required 

Citation: Comp. Laws § 712A.18f

Reasonable efforts must be made:

• To prevent the child’s removal from his or her home

• To rectify conditions that caused removal of the child from his or her home

When Reasonable Efforts Are NOT Required 

Citation: Comp. Laws §§ 712A.19a; 722.638

Reasonable efforts to reunify the child and family must be made in all cases, except when any of the following apply:

• There is a judicial determination that the parent has subjected the child to aggravated circumstances, as provided in 

§ 722.638, including:

» Abandonment of a young child

» Criminal sexual conduct involving penetration, attempted penetration, or assault with intent to penetrate 

» Battering, torture, or other severe physical abuse

» Loss or serious impairment of an organ or limb
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» Life-threatening injury

• The parent has been convicted of one or more of the following:

» Murder of another child of the parent

» Voluntary manslaughter of another child of the parent

» Aiding or abetting in the murder or voluntary manslaughter of another child of the parent, the attempted murder of the 

child or another child of the parent, or the conspiracy or solicitation to commit the murder of the child or another child of the 

parent

» A felony assault that results in serious bodily injury to the child or another child of the parent

• The parent is required by court order to register under the sex offenders registration act.

• The parent has had rights to the child’s siblings involuntarily terminated.

Minnesota

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 260.012

Reasonable efforts are made upon the exercise of due diligence by the responsible social services agency to use culturally appropriate 

and available services to meet the needs of the child and the child’s family. Services may include those provided by the responsible 

social services agency and other culturally appropriate services available in the community.

When determining whether reasonable efforts have been made, the court shall consider whether services to the child and family were:

• Relevant to the safety and protection of the child

• Adequate to meet the needs of the child and family

• Culturally appropriate

• Available and accessible 

• Consistent and timely

• Realistic under the circumstances

In the case of an Indian child, the responsible social services agency must provide active efforts, as required by the Indian Child 

Welfare Act of 1978.

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 260.012

The social services agency has the burden of demonstrating that:

• It has made reasonable efforts to prevent placement of the child in foster care.

• It has made reasonable efforts to eliminate the need for removal of the child from the child’s home and to reunify the child with 

the child’s family at the earliest possible time.

• It has made reasonable efforts to finalize an alternative permanent home for the child, and it has considered permanent 

alternative homes for the child inside or outside of the State.

• Reasonable efforts to prevent placement and to reunify the child with the parent or guardian are not required.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 260.012

Reasonable efforts always are required except when:

• A parent has subjected the child to egregious harm.

• The parent’s parental rights to another child have been terminated involuntarily.

• The child is an abandoned infant.

• The parent’s custodial rights have been involuntarily transferred to another relative.

• A determination has been made that additional reasonable efforts would be futile and unreasonable under the circumstances.

• The parent has been convicted of murder, manslaughter, assault, or assault with substantial bodily injury, or an attempt or 

conspiracy to commit any of these crimes, and the victim was another child of the parent.

• The parent has committed sexual abuse against the child or another child of the parent.

• The parent has committed an offense that requires registration as a predatory offender under § 243.166, subd. 1b.

• The parent has been convicted of assault or assault with substantial bodily injury, and the victim was the surviving child.
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Mississippi

What Are Reasonable Efforts? 

Citation: Ann. Code § 43-51-3

Family preservation services are services designed to help families alleviate risks or crises that might lead to out-of-home placement 

of children. The services may include procedures to maintain the safety of children in their own homes, support to families preparing 

to reunify or adopt, and assistance to families in obtaining services and other sources of support necessary to address their multiple 

needs in a culturally sensitive environment.

Family support services are preventive community-based activities designed to alleviate stress and to promote parental 

competencies and behaviors that will increase the ability of families to successfully nurture their children and will enable families 

to use other resources and opportunities available in the community. These services may include supportive networks designed 

to enhance child-rearing abilities of parents and to help compensate for the increased social isolation and vulnerability of families. 

Examples of these services and activities include:

• Respite care for parents and other caregivers

• Early developmental screening of children to assess their needs and assistance in obtaining specific services to meet their 

needs

• Mentoring, tutoring, and health education for youth

• A range of center-based activities, such as informal interactions in drop-in centers and parent support groups and home 

visiting programs

When Reasonable Efforts Are Required 

Citation: Ann. Code § 43-21-609

If the child has not been taken into care previously, the court shall determine:

• Reasonable efforts have been made to maintain the child within his or her own home unless the circumstances warrant his or 

her removal, and there is no reasonable alternative to custody.

• The circumstances are of such an urgent nature that no reasonable efforts have been made to maintain the child within his or 

her own home, and there is no reasonable alternative to custody.

If the court finds that the child should be taken into care, the court shall order that reasonable efforts be made toward the 

reunification of the child with his or her family.

If the child has been taken into care before the disposition hearing, the court shall determine whether reasonable efforts were 

made by the Department of Human Services to finalize the child’s permanency plan that was in effect on the date of the disposition 

hearing.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 43-21-603(7)

Reasonable efforts to maintain the child within his or her home shall not be required if the court determines that:

• The parent has subjected the child to aggravated circumstances, including, but not limited to, abandonment, torture, chronic 

abuse, and sexual abuse.

• The parent has been convicted of murder or voluntary manslaughter of another child of that parent; aiding, abetting, 

attempting, conspiring, or soliciting to commit that murder or voluntary manslaughter; or a felony assault that results in the 

serious bodily injury to the surviving child or another child of that parent.

• The parental rights of the parent to a sibling have been terminated involuntarily.

• Continuation of the child’s residence within his or her own home would be contrary to the welfare of the child, and placement 

of the child in foster care is in the best interests of the child.

Missouri

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 211.183

The term ‘reasonable efforts’ means the exercise of reasonable diligence and care by the Children’s Division to utilize all available 

services related to meeting the needs of the juvenile and the family. 
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When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 211.183

Reasonable efforts must be made:

• To prevent or eliminate the need for the removal of the child

• After removal, to make it possible for the child to return home

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 211.183

The division shall not be required to make reasonable efforts, but it has the discretion to make reasonable efforts if the court has 

determined that:

• The parent has subjected the child to severe or recurrent acts of physical, emotional, or sexual abuse, including an act of incest.

• The parent has committed murder or voluntary manslaughter of another child of the parent, or aided, abetted, or attempted 

such act.

• The parent has committed a felony assault that resulted in serious bodily injury to the child or to another child of the parent.

• The parent’s parental rights to a sibling have been terminated involuntarily.

Montana

What Are Reasonable Efforts? 

Citation: Ann. Code § 41-3-423

Reasonable efforts include, but are not limited to:

• Voluntary protective services agreements

• Development of individual written case plans specifying State efforts to reunify families 

• Placement in the least disruptive setting possible

• Provision of services pursuant to a case plan

• Periodic review to ensure timely progress

When Reasonable Efforts Are Required 

Citation: Ann. Code § 41-3-423

The Department of Public Health and Human Services shall make reasonable efforts:

• To prevent the necessity of removal of a child from a child’s home

• To reunify families that have been separated

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 41-3-423

Reasonable efforts are not required if a court finds by clear and convincing evidence that a parent has:

• Subjected a child to aggravated circumstances, including abandonment, torture, chronic abuse, sexual abuse, or chronic and 

severe neglect

• Committed, aided, abetted, or attempted to commit homicide of a child

• Committed aggravated assault against a child

• Committed neglect of a child that resulted in serious bodily injury or death

• Had parental rights to a sibling terminated involuntarily, and circumstances of the termination are relevant to the parent’s ability 

to adequately care for the child at issue

Preservation or reunification services are not required for a putative father if the court finds that the putative father has failed to do 

any of the following:

• Contribute to the support of the child for an aggregate period of 1 year, although able to do so

• Establish a substantial relationship with the child, as demonstrated by:

» Visiting the child at least monthly when physically and financially able to do so

» Having regular contact with the child

» Manifesting an ability and willingness to assume legal and physical custody of the child if the child was not in the physical 

custody of the other parent

• Register with the putative father registry, been adjudicated to be the father of the child for the purposes of child support, or 

been recorded on the child’s birth certificate as the child’s father
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Nebraska

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 43-532(2)

When children and families require assistance from a State department or agency, the health and safety of the child is the paramount 

concern, and reasonable efforts shall be made to provide such assistance in the least intrusive and least restrictive method 

consistent with the needs of the child and to deliver such assistance as close to the home community of the child or family requiring 

assistance as possible.

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 43-283.01

Reasonable efforts shall be made:

• Prior to placement to prevent or eliminate the need for removing the juvenile from the home

• To make it possible for the juvenile to return home safely

• To place the juvenile in a timely manner and to finalize a permanent placement if continuation of reasonable efforts is 

determined to be inconsistent with the permanency plan

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. § 43-283.01

Reasonable efforts to preserve and reunify the family are not required if the court has determined that:

• The parent has subjected the juvenile or another minor child to aggravated circumstances, including abandonment, torture, 

chronic abuse, or sexual abuse.

• The parent has committed murder or voluntary manslaughter of another child, or aided, abetted, or attempted to commit 

such a crime. 

• The parent has committed felony assault resulting in serious bodily injury to the child or another child.

• The parent has been convicted of felony sexual assault of the other parent of the child.

• The parent’s parental rights to another child have been terminated involuntarily.

Nevada

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 432B.393

For the purposes of this section, ‘reasonable efforts’ have been made if an agency that provides child welfare services that has legal 

custody of a child has exercised diligence and care in arranging appropriate, accessible, and available services that are designed to 

improve the ability of a family to provide a safe and stable home for each child in the family, with the health and safety of the child as 

its paramount concerns. An agency may satisfy the requirement of making reasonable efforts pursuant to this section by taking no 

action concerning a child or making no effort to provide services to a child if it is reasonable, under the circumstances, to do so.

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 432B.393

Reasonable efforts must be made:

• Before placement of the child in foster care to prevent or eliminate the need for removal from the home

• To make it possible to return home safely

• If continuation of reasonable efforts is determined to be inconsistent with the permanency plan, to place the child in a timely 

manner, and to finalize a permanent placement

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. § 432B.393

Reasonable efforts are not required if the court finds that:

• A parent or other person responsible for the child’s welfare has:

» Committed, aided, or abetted in the commission of, or attempted, conspired, or solicited to commit murder or voluntary 

manslaughter

» Caused the abuse or neglect of the child, which resulted in substantial bodily harm to the child
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» Caused the abuse or neglect of the child, and the abuse or neglect was so extreme or repetitious that returning the child 

to the home would result in an unacceptable risk to the child’s health or welfare

» Abandoned the child for 60 or more days, and the identity of the parent is unknown

• A parent of the child has, for the previous 6 months, had the ability to contact or communicate with the child and made no 

more than token efforts to do so.

• The parental rights of a parent to another child have been terminated involuntarily by a court order, and the court order is not 

currently being appealed.

• The child or a sibling of the child was previously removed from the home due to abuse or neglect, returned to the home, and 

subsequently removed from the home as a result of additional abuse or neglect.

• The child is less than age 1, the father of the child is not married to the child’s mother, and the father:

» Has failed within 60 days after learning of the birth of the child, to visit the child, to commence proceedings to establish his 

paternity of the child, or to provide financial support for the child

» Is entitled to seek custody of the child, but fails to do so within 60 days after learning that the child was placed in foster 

care

• The child was delivered to a provider of emergency services.

• The child or another child in the household has been sexually abused or has been subjected to neglect by pervasive instances 

of failure to protect the child from sexual abuse.

• A parent of the child is required to register as a sex offender.

New Hampshire

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 169-C:24-a

Reasonable efforts are services to the family that are accessible, available, and appropriate. 

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 169-C:24-a

Reasonable efforts must be made:

• To prevent placement

• To reunify the family

• To make and finalize a new permanent home for the child

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. § 169-C:24-a

The State agency shall discontinue reasonable efforts and file a petition for termination of parental rights when one or more of the 

following circumstances exist:

• The child has been in an out-of-home placement due to a finding of child neglect or abuse for 12 of the most recent 

22 months.

• The court has determined that the child has been abandoned.

• The parent has been convicted of murder of another child of the parent, a sibling or stepsibling of the child, the child’s other 

parent, or other persons related by consanguinity or affinity, including a minor child who resided with the defendant.

• The parent has been convicted of manslaughter of another child of the parent.

• The parent has been convicted of attempt, solicitation, or conspiracy to commit any of the offenses specified above.

• The parent has been convicted of a felony assault that resulted in injury to the child, a sibling or stepsibling of the child, 

the child’s other parent, or other persons related by consanguinity or affinity, including a minor child who resided with the 

defendant.
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New Jersey

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 30:4C-15.1

The term ‘reasonable efforts’ means attempts by an agency to assist parents in remedying the circumstances and conditions that led 

to placement of the child and to reinforce family structure, including:

• Consultation with the parent in developing a plan for appropriate services 

• Providing the services agreed upon

• Informing the parent of the child’s progress, development, and health

• Facilitating appropriate visitation

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 30:4C-11.1

Reasonable efforts must be made:

• Prior to placement, to preserve the family in order to prevent the need for removing the child from the home

• After placement, to make it possible for the child to return home safely

• In any case where reunification is not the permanency plan, to place the child in a timely manner and finalize the permanent 

placement of the child

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. §§ 30:4C-11.2; 30:4C-11.3

Reasonable efforts to reunify the child with the family are not required when:

• The parent has subjected the child to aggravated circumstances of abuse, neglect, cruelty, or abandonment.

• The parent has been convicted of murder or manslaughter of a child; aiding, abetting, or attempting to commit such a crime; 

or committing or attempting to commit an assault resulting in serious bodily injury to a child.

• The parent’s parental rights to another child have been terminated involuntarily.

Reasonable efforts to prevent placement are not required when:

• Removal of the child was necessary due to imminent danger to the child’s life, safety, or health.

• Efforts to prevent placement were not reasonable due to risk of harm to the child’s health or safety.

New Mexico

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 32A-4-21 

Reasonable efforts may include:

• An intervention plan designed to achieve placement of the child in the least restrictive setting available, consistent with the 

best interests and special needs of the child, including a statement of the likely harm the child may suffer as a result of being 

removed from the parents’ home, including emotional harm that may result due to separation from the child’s parents, and a 

statement of how the intervention plan is designed to place the child in close proximity to the parents’ home without causing 

harm to the child due to separation from parents, siblings, or any other person who may significantly affect the child’s best 

interests 

• Services offered to the child, his or her family, and the foster care family

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 32A-4-22

Reasonable efforts shall be made:

• To prevent the removal of the child from the child’s family

• To reunite the child with the child’s family

• To place siblings in custody together, unless such joint placement would be contrary to the safety or well-being of any of the 

siblings in custody

• For siblings not jointly placed, to provide reasonable visitation or other ongoing interaction unless visitation or other ongoing 

interaction would be contrary to the safety or well-being of any of the siblings

• To implement and finalize the permanency plan in a timely manner when reasonable efforts to reunify are not required
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When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. §§ 32A-4-2; 32A-4-22

Reasonable efforts are not required when:

• The efforts would be futile.

• The parent has subjected the child to aggravated circumstances.

Aggravated circumstances are those in which the parent, guardian, or custodian has:

• Attempted, conspired to cause, or caused great bodily harm to the child or great bodily harm or death to the child’s sibling

• Attempted, conspired to cause, or caused great bodily harm or death to another parent, guardian, or custodian of the child

• Attempted, conspired to subject, or has subjected the child to torture, chronic abuse, or sexual abuse

• Had parental rights over a sibling of the child terminated involuntarily

New York

What Are Reasonable Efforts? 

Citation: Soc. Serv. Law § 384-b(7)(f)

The term ‘diligent efforts’ means reasonable attempts by an agency to assist, develop, and encourage a meaningful relationship 

between the parent and child, which include but are not limited to: 

• Consulting and cooperating with the parents to develop a plan for appropriate services

• Making suitable arrangements for the parent to visit with the child

• Providing services and other assistance so that problems preventing the child’s discharge from care can be resolved

• Informing the parents of the child’s progress, development, and health

• Making suitable arrangements with a correctional facility for an incarcerated parent to visit with the child, if such visiting is in 

the best interests of the child

When Reasonable Efforts Are Required 

Citation: Soc. Serv. Law § 358-a(3)(a)

Reasonable efforts must be made:

• Prior to placement to prevent or eliminate the need for removal of the child from the home

• To make it possible for the child to return home

• If the permanent plan for the child is other than reunification, to make and finalize the alternative permanent placement

When Reasonable Efforts Are NOT Required 

Citation: Soc. Serv. Law §§ 358-a(3)(b); 384-b(7)(e)

Reasonable efforts are not required when the court determines that:

• The parent has subjected the child to aggravated circumstances, where the child has been either severely or repeatedly 

abused.

• The parent has been convicted of murder or manslaughter, and the victim was another child of the parent. However, the 

parent must have acted voluntarily in committing such crime.

• The parent has been convicted of an attempt to commit any of the above crimes, and the victim or intended victim was the 

child or another child of the parent; or has been convicted of conspiring, soliciting, or facilitating any of the above crimes, and 

the victim or intended victim was the child or another child of the parent.

• The parent has been convicted of assault or aggravated assault upon a person younger than age 11, and the crime resulted in 

serious physical injury to the child or another child of the parent.

• The parental rights of the parent to a sibling of the child have been involuntarily terminated.

Evidence of diligent efforts by an agency to encourage and strengthen the parental relationship shall not be required when:

• The parent has failed for a period of 6 months to keep the agency apprised of his or her location.

• An incarcerated parent has failed on more than one occasion while incarcerated to cooperate with an authorized agency in its 

efforts to help the parent plan for the future of the child or in the agency’s efforts to plan and arrange visits with the child.
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North Carolina

What Are Reasonable Efforts? 

Citation: Gen. Stat. § 7B-101

The term ‘reasonable efforts’ means the diligent use of abuse prevention or reunification services by the Department of Social 

Services when a juvenile remaining at home or returning home is consistent with achieving a safe, permanent home for the juvenile 

within a reasonable period of time. If a court of competent jurisdiction determines that the juvenile is not to be returned home, then 

reasonable efforts are the diligent and timely use of permanency planning services by a department of social services to develop and 

implement a permanent plan for the juvenile.

When Reasonable Efforts Are Required 

Citation: Gen. Stat. § 7B-101

Reasonable efforts must be made:

• To prevent or eliminate the need for placement of the juvenile out of the home 

• To develop and implement a permanent plan for the child when a court determines that the juvenile is not to be returned home

When Reasonable Efforts Are NOT Required 

Citation: Gen. Stat. § 7B-901

The court shall direct that reasonable efforts for reunification shall not be required if the court makes written findings of fact 

pertaining to any of the following:

• A court has determined that aggravated circumstances exist because the parent has committed, encouraged the commission 

of, or allowed the continuation of any of the following upon the juvenile:

» Sexual abuse

» Chronic physical or emotional abuse

» Torture

» Abandonment 

» Chronic or toxic exposure to alcohol or controlled substances that causes impairment of or addiction in the juvenile

» Any other act, practice, or conduct that increased the enormity or added to the injurious consequences of the abuse or 

neglect

• A court has terminated involuntarily the parental rights of the parent to another child of the parent.

• A court has determined that the parent:

» Has committed murder or voluntary manslaughter of another child of the parent

» Has aided, abetted, attempted, conspired, or solicited to commit murder or voluntary manslaughter of the child or another 

child of the parent

» Has committed a felony assault resulting in serious bodily injury to the child or another child of the parent

» Has committed sexual abuse against the child or another child of the parent 

» Has been required to register as a sex offender on any government-administered registry

North Dakota

What Are Reasonable Efforts? 

Citation: Cent. Code § 27-20-32.2

The term ‘reasonable efforts’ means the exercise, by the agency granted authority over the child of due diligence in using appropriate 

and available services to meet the needs of the child and his or her family in order to prevent removal of the child from the child’s 

family or, after removal, to use appropriate and available services to eliminate the need for removal, to reunite the child and his or her 

family, and to maintain family connections. In determining reasonable efforts to be made with respect to a child under this section, 

and in making reasonable efforts, the child’s health and safety must be the paramount concern. 

When Reasonable Efforts Are Required 

Citation: Cent. Code § 27-20-32.2

Reasonable efforts must be made to preserve families, reunify families, and maintain family connections:

• Prior to the placement of a child in foster care, to prevent or eliminate the need for removing the child from his or her home

• To make it possible for a child to return safely to his or her home
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• To place siblings in the same foster care, relative, guardianship, or adoptive placement, unless it is determined that such a 

joint placement would be contrary to the safety or well-being of any of the siblings

• In the case of siblings removed from their home who are not jointly placed, to provide for frequent visitation or other ongoing 

visitation between the siblings, unless it is contrary to the safety or well-being of any of the siblings

If the court determines that continuation of reasonable efforts is inconsistent with the permanency plan for the child, reasonable 

efforts must be made to place the child in a timely manner in accordance with the permanency plan and to complete whatever steps 

are necessary to finalize the permanent placement of the child.

For the purpose of § 27-20-30.1 [concerning continued foster care for older youth], reasonable efforts must be made to meet the 

child’s needs before a foster care placement for a child remaining in care for continued foster care purposes. 

When Reasonable Efforts Are NOT Required 

Citation: Cent. Code §§ 27-20-02; 27-20-32.2

Reasonable efforts are not required if:

• The parent has subjected the child to aggravated circumstances, in which a parent:

» Abandons, tortures, chronically abuses, or sexually abuses a child

» Fails to make substantial efforts to secure treatment for an addiction, mental illness, or other condition for 1 year or 

one-half a child’s lifetime, whichever time period is less

» Engages in deviant sexual acts, sexual abuse, etc., in which the victim is a child

» Commits murder, manslaughter, or negligently causing the death of another, or the attempt to commit such crimes, and 

the victim is another child of the parent

» Commits aggravated assault in which the victim is a child of the parent and suffers serious bodily injury

» Commits assault, aggravated assault, reckless endangerment, or terrorizing in which a child is the victim or intended victim

» Has been incarcerated under a sentence for which the release date is:

○ In the case of a child age 9 older, after the child’s majority 

○ In the case of a child under age 9, after the child is twice the child’s current age

» Subjects the child to prenatal exposure to chronic or severe use of alcohol or any controlled substance in a manner not 

lawfully prescribed by a practitioner

» Allows the child to be present in an environment subjecting the child to exposure to a controlled substance, chemical 

substance, or drug paraphernalia

• The parent has had parental rights to another child terminated involuntarily.

Northern Mariana Islands

What Are Reasonable Efforts?

This issue is not addressed in the statutes reviewed. 

When Reasonable Efforts Are Required

This issue is not addressed in the statutes reviewed. 

When Reasonable Efforts Are NOT Required

This issue is not addressed in the statutes reviewed. 

Ohio

What Are Reasonable Efforts? 

Citation: Rev. Code § 2151.419

Reasonable efforts are relevant services provided by the child welfare agency to the family of the child. 

When Reasonable Efforts Are Required 

Citation: Rev. Code § 2151.419

Reasonable efforts must be made:

• To prevent removal of the child from the home

• To eliminate the continued removal of the child from home

• To make it possible for the child to return safely home
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When Reasonable Efforts Are NOT Required 

Citation: Rev. Code § 2151.419

The court shall determine that reasonable efforts are not required if any of the following apply:

• The parent from whom the child was removed has been convicted of or pleaded guilty to one of the following:

» Murder or voluntary manslaughter of another child in the household

» Assault, endangering children, rape, sexual battery, corruption of a minor, or sexual imposition of the child or another child 

in the household

» Trafficking in persons, compelling prostitution, or promoting prostitution of the child, a sibling of the child, or another child 

who lived in the parent’s household at the time of the offense

» Conspiracy, attempt to commit, or complicity in committing, an offense described above

• The parent has repeatedly withheld medical treatment or food from the child.

• The parent has placed the child at substantial risk of harm two or more times due to drug or alcohol abuse and has rejected 

treatment two or more times.

• The parent has abandoned the child.

• The parent’s parental rights to another child have been terminated involuntarily.

Oklahoma

What Are Reasonable Efforts? 

Citation: Ann. Stat. Tit. 10A, § 1-4-808

The court shall determine whether the nature and extent of services being provided to the child and the child’s parent(s) are 

adequate to ensure the safety of the child and to protect the child from further physical, mental, or emotional harm, or to correct the 

conditions that led to the adjudication.

When Reasonable Efforts Are Required 

Citation: Ann. Stat. Tit. 10A, §§ 1-1-102; 1-4-807

Reasonable efforts are required:

• To prevent the removal of the child from the child’s home 

• To provide for the safe return of the child to the child’s own home

• To place the child in a timely manner in accordance with the permanency plan when the court has determined that reasonable 

efforts to reunite the child with his or her family are not required

• To place siblings, when they have been removed from home, together in the same foster care, guardianship, or adoptive 

placement

• To provide for frequent visitation or other ongoing interaction in the case of siblings who have been removed and who are not 

placed together

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. Tit. 10A, § 1-4-809

Reasonable efforts are not required if the court finds, based upon a preponderance of the evidence, that:

• The parent or legal guardian of the child who is an infant age 12 months or younger has abandoned the child.

• The parent or legal guardian of the child has:

» Committed murder or manslaughter of any child

» Aided or abetted, attempted, conspired, or solicited to commit the murder or manslaughter of any child 

» Committed a felony assault upon any child that resulted in serious bodily injury 

» Subjected any child to aggravated circumstances, including, but not limited to, heinous and shocking abuse or neglect

• The parental rights of a parent to the child’s sibling have been terminated involuntarily.

• The parent has been found by a court of competent jurisdiction to have committed sexual abuse against the child or another 

child of the parent.

• The parent is required to register with a sex offender registry pursuant to § 113(a) of the Adam Walsh Child Protection and 

Safety Act of 2006 (42 U.S.C. § 16913(a)).
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Oregon

What Are Reasonable Efforts? 

Citation: Rev. Stat. § 419B.340

Reasonable efforts include preventive and reunification services. 

For an Indian child, the Department of Human Services must make active efforts to provide remedial services and rehabilitative 

programs designed to prevent the breakup of the Indian family. 

When Reasonable Efforts Are Required 

Citation: Rev. Stat. § 419B.340

Reasonable efforts must be made:

• To prevent or eliminate the need for removal of the child from the home

• To make it possible for the child to return home safely

When Reasonable Efforts Are NOT Required 

Citation: Rev. Stat. § 419B.340

The court may find that the department is not required to make reasonable efforts if one of the following circumstances exists: 

• The parent has subjected the child to aggravated circumstances including, but not limited to, the following:

» The parent by abuse or neglect has caused the death of any child.

» The parent has attempted, solicited, or conspired to cause the death of any child.

» The parent by abuse or neglect has caused serious physical injury to any child.

» The parent has subjected any child to rape, sodomy, or sexual abuse.

» The parent has subjected any child to intentional starvation or torture.

» The parent has abandoned the child. 

» The parent has unlawfully caused the death of the other parent of the child.

• The parent has been convicted in any jurisdiction of one of the following crimes:

» Murder or manslaughter of another child of the parent

» Aiding, abetting, attempting, conspiring, or soliciting to commit any such crime

» Felony assault that results in serious physical injury to the child or another child of the parent

• The parent’s rights to another child have been terminated involuntarily.

Pennsylvania

What Are Reasonable Efforts? 

Citation: Cons. Stat. Tit. 23, § 6373; Tit. 42, § 6351

Reasonable efforts include:

• Efforts to assist the child and the child’s parent

• Preventive services

When Reasonable Efforts Are Required 

Citation: Cons. Stat. Tit. 23, § 6373; Tit. 42, § 6351

Reasonable efforts must be made:

• To prevent or eliminate the need for removal of the child from the home

• To make it possible for the child to return home

• To finalize the permanency plan in effect

• To place siblings together unless a joint placement is contrary to the safety or well-being of the child or sibling

If a sibling of a child has been removed from his home and is in a different placement setting than the child, the court shall enter 

an order that ensures visitation between the child and the child’s sibling no less than twice a month, unless a finding is made that 

visitation is contrary to the safety or well-being of the child or sibling. 
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When Reasonable Efforts Are NOT Required 

Citation: Cons. Stat. Tit. 42, §§ 6351; 6302

Reasonable efforts are not required if the court has determined that aggravated circumstances exist and no new or additional efforts 

are required. Aggravated circumstances include any of the following:

• The child is in the custody of a county agency, the identity or location of the parents is unknown, and the parent does not 

claim the child within 3 months or has failed to maintain contact for a period of 6 months.

• The child or another child of the parent has been the victim of serious physical abuse, sexual violence, or aggravated physical 

neglect by the parent.

• The parent has been convicted of any of the following crimes in which the victim was a child: criminal homicide, aggravated 

assault, rape, statutory sexual assault, indecent assault, or the attempt to commit any such crime.

• The parent’s parental rights to another child have been terminated involuntarily.

Puerto Rico

What Are Reasonable Efforts? 

Citation: Ann. Laws Tit. 8, § 447s

The Department of the Family shall make use of resources for the support of individuals, families, and the community, as well as 

internal and external resources of the department and other public and nongovernmental agencies, to improve the living conditions 

of families that may endanger the life and safety of a minor.

When Reasonable Efforts Are Required 

Citation: Ann. Laws Tit. 8, § 447s

Reasonable efforts shall be made to ensure the well-being and full protection of the minor and to preserve the integrity of the family 

prior to the removal of a minor from his or her home. After removing a minor from his or her home, reasonable efforts shall be made 

for a period not to exceed 6 months to reunite the minor with his or her family. Moreover, support services shall continue once the 

minor is permanently placed.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Laws Tit. 8, § 447s

No reasonable efforts shall be undertaken under the following circumstances:

• The parent suffers from a mental disability of such a magnitude that it prevents the parent from caring properly for the child.

• The child has been previously removed from the home, and after being returned home, he or she is again made a victim of 

abuse, sexual abuse, and/or neglect.

• The parent has been deprived of patria potestas of another child and has been unable to resolve the problems that led to the 

loss of patria potestas.

• The parent has caused severe physical harm, abuse, and/or neglect of the child, putting the child’s health and physical, 

mental, and emotional integrity at grave risk.

• The parent has committed:

» Murder, assault, or mutilation

» Rape, incest, or lewd or obscene acts

» Trafficking of individuals for sexual purposes

» Remittance, transportation, sale, distribution, publication, exhibition, or possession of obscene materials or obscene 

shows, and exposing minors to those crimes

» Kidnapping or aggravated kidnapping

» Abandonment of minors

» Abduction or perversion of minors

» Inciting a minor to commit a crime

• The parent covers up or conspires to commit one or more of the crimes above.

• Efforts to change the behavior of the parent have not succeeded 6 months after the service plan was initiated. 

• The parent has stated that he or she has no interest in being reunited with the minor.

• A health-care professional certifies that the parent suffers from a chronic controlled substance abuse problem that prevents 

the return of the minor to the custody of the parent within a period of 6 months of initiating the procedures.
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Rhode Island

What Are Reasonable Efforts? 

Citation: Gen. Laws § 40-11-12.2

Reasonable efforts are measures taken to preserve and reunify families. 

When Reasonable Efforts Are Required 

Citation: Gen. Laws § 40-11-12.2

Reasonable efforts must be made:

• Prior to placement of a child in foster care to prevent or eliminate the need for removing the child from the home that may 

include placement of the child with a relative 

• To make it possible for the child to return home safely

• If continuation of efforts is determined to be inconsistent with the permanency plan for the child, to place the child in a timely 

manner and finalize a permanent placement

When Reasonable Efforts Are NOT Required 

Citation: Gen. Laws § 40-11-12.2

Reasonable efforts are not required if a court determines that: 

• The parent has subjected any child to conduct of a cruel and abusive nature.

• The parent has:

» Committed murder of another child of the parent

» Subjected the child to aggravating circumstances, including abandonment, torture, chronic abuse, or sexual abuse

» Committed voluntary manslaughter of another child of the parent or attempted to commit such crime

» Committed a felony assault that results in serious bodily injury of the child or another child of the parent

• The parent’s parental rights to a sibling of the child have been terminated involuntarily.

South Carolina

What Are Reasonable Efforts? 

Citation: Ann. Code § 63-7-1680

Reasonable efforts include services that are reasonably available and timely, reasonably adequate to address the needs of the family, 

reasonably adequate to protect the child, and realistic under the circumstances. 

When Reasonable Efforts Are Required 

Citation: Ann. Code §§ 63-7-720; 63-7-1640

Reasonable efforts must be made by the Department of Social Services to prevent removal of the child unless the court finds that 

continuation of the child in the home would be contrary to the welfare of the child.

The family court may rule on whether reasonable efforts to preserve or reunify a family should be required in hearings regarding 

removal of custody, review of amendments to a placement plan, review of the status of a child in foster care, permanency planning, 

or in a separate proceeding for this purpose.

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 63-7-1640

The department may terminate or forego reasonable efforts to preserve or reunify a family when the family court determines that 

one or more of the following conditions exist:

• The parent has subjected the child or another child while residing in the parent’s domicile to one or more of the following 

aggravated circumstances:

» Severe or repeated abuse or neglect

» Sexual abuse 

» Torture

» Abandonment

• The parent has been convicted of murder or voluntary manslaughter of another child.
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• The parent has been convicted of aiding, abetting, attempting, soliciting, or conspiring to commit murder or voluntary 

manslaughter of the child or another child while residing in the parent’s domicile.

• Physical abuse of a child resulted in the death or admission to the hospital for in-patient care of that child, and the abuse was 

committed by the parent.

• The parent has been convicted of committing, aiding, abetting, conspiring to commit, or soliciting:

» An offense against the person 

» Criminal domestic violence

» Criminal domestic violence of a high and aggravated nature

» Assault and battery of a high and aggravated nature

• The parental rights of the parent to another child of the parent have been terminated involuntarily.

• The parent has a diagnosable condition unlikely to change within a reasonable time including, but not limited to, alcohol or 

drug addiction, mental deficiency, mental illness, or extreme physical incapacity, and the condition makes the parent unable 

or unlikely to provide minimally acceptable care of the child.

• Other circumstances exist that the court finds make continuation or implementation of reasonable efforts to preserve or 

reunify the family inconsistent with the permanent plan for the child.

South Dakota

What Are Reasonable Efforts?

Citation: Ann. Laws § 26-8A-21

The term ‘reasonable efforts’ means the provision by the Department of Social Services of any services or assistance that:

• Are appropriate for the child’s parents, including instruction on parenting

• Are available or could be made available without undue financial burden on the department

• Would have a significant likelihood of protecting the child from substantial danger to his or her physical health or from severe 

emotional damage while enabling the child to remain in the home or to be returned to the home

When Reasonable Efforts Are Required

Citation: Ann. Laws § 26-8A-21

Reasonable efforts must be made:

• Prior to removal of an alleged or adjudicated abused or neglected child to prevent or eliminate the need for removal from the 

home

• To make it possible for the child to return home if he or she has been removed from the home

When Reasonable Efforts Are NOT Required 

Citation: Ann. Laws § 26-8A-21.1

Reasonable efforts to reunify are not required when the parent: 

• Has committed murder, manslaughter, rape, incest, sexual exploitation of a minor, or abuse or cruelty to a minor

• Committed aggravated assault against the child or another child of the parent

• Has subjected the child or another child to torture or sexual abuse; abandonment for at least 6 months; chronic physical, 

mental, or emotional injury; or chronic neglect

• Is incarcerated and unavailable to care for the child during a significant period of the child’s minority 

• Has had parental rights to another child terminated involuntarily 

• Has a documented history of abuse or neglect associated with chronic alcohol or drug abuse

• Has exposed the child to or demonstrated an inability to protect the child from substantial harm or the risk of substantial 

harm, and the child or another child has been removed from the parent’s custody because he or she was adjudicated abused 

and neglected by a court on at least one previous occasion

• Has exposed the child to or demonstrated an inability to protect the child from substantial harm or the risk of substantial 

harm, the child has been removed from the parent’s custody on two separate occasions, and the department offered or 

provided family services on each of the two separate occasions the child was removed

• Has exposed the child to or demonstrated an inability to protect the child from substantial harm or risk of harm resulting from 

a crime, act, or omission listed above

• Is required to register as a sex offender pursuant to Chapter 22-24B
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Tennessee

What Are Reasonable Efforts?

Citation: Ann. Code § 37-1-166

The term ‘reasonable efforts’ means the exercise of reasonable care and diligence by the Department of Children’s Services to 

provide services related to meeting the needs of the child and the family. 

When Reasonable Efforts Are Required

Citation: Ann. Code § 37-1-166

Reasonable efforts must be made:

• To prevent the need for removal of the child from the child’s family

• To make it possible for the child to return home

• To place the child in a timely manner in accordance with the permanency plan and to complete whatever steps are necessary 

to finalize the permanent placement of the child if continuation of reasonable efforts is determined to be inconsistent with the 

permanency plan for the child

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code §§ 36-1-102(9); 37-1-166

Reasonable efforts shall not be required if a court has determined that:

• The parent has subjected the child or any child in the household to aggravated circumstances, including: 

» Abandonment or abandonment of an infant 

» Aggravated assault

» Aggravated kidnapping or especially aggravated kidnapping

» Aggravated child abuse and neglect

» Aggravated sexual exploitation of a minor or especially aggravated sexual exploitation of a minor 

» Aggravated rape, rape, rape of a child, or incest

» Severe child abuse, as defined in § 37-1-102

• The parent has committed murder or manslaughter of any sibling or other child residing in the household, or aided, abetted, 

or attempted such crime.

• The parent has committed a felony assault that resulted in serious bodily injury to any child residing in the household.

• The parental rights of the parent to another child have been terminated involuntarily.

Texas

What Are Reasonable Efforts? 

Citation: Family Code § 262.001

In determining the reasonable efforts that are required to be made with respect to preventing or eliminating the need to remove 

a child from the child’s home or to make it possible to return a child to the child’s home, the child’s health and safety are the 

paramount concerns.

When Reasonable Efforts Are Required 

Citation: Family Code §§ 262.001; 262.2015

Reasonable efforts must be made:

• To prevent or eliminate the need to remove a child from the child’s home

• To make it possible for the child to return home

• To finalize the permanent placement of a child for whom the court has made a finding that reasonable efforts to return the 

child home are not required
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When Reasonable Efforts Are NOT Required 

Citation: Family Code § 262.2015

The court may waive the requirement to make reasonable efforts if the court finds that the parent has subjected the child to 

aggravated circumstances such as the following:

• The parent abandoned the child without a means of identifying the child.

• The child or another child of the parent is a victim of serious bodily injury or sexual abuse inflicted by the parent or another 

person with the parent’s consent.

• The parent has engaged in conduct against the child or another child of the parent that would constitute the offense of 

murder, manslaughter, indecency with a child, sexual assault, aggravated assault, injury to a child, abandoning or endangering 

a child, prohibited sexual conduct, sexual performance by a child, possession or promotion of child pornography, continuous 

sexual abuse of a child, compelling prostitution, or trafficking of persons. 

• The parent voluntarily left the child alone or in the possession of another person for at least 6 months without expressing the 

intent to return and without providing adequate support for the child.

• The parent’s parental rights to another child of the parent have been terminated involuntarily based on a finding that the 

parent knowingly placed or allowed the child to remain in conditions or surroundings, or with persons engaged in conduct, 

that endangered the child’s physical or emotional well-being.

• The parent has been convicted for the murder or voluntary manslaughter of another child, or aiding, abetting, or attempting 

such crime.

• The parent has been convicted of a felony assault that resulted in serious bodily injury of the child or another child of the 

parent.

• The parent’s parental rights with regard to two other children have been involuntarily terminated.

• The parent is required under any State or Federal law to register with a sex offender registry.

Utah

What Are Reasonable Efforts? 

Citation: Ann. Code § 78A-6-312

The Division of Child and Family Services shall make reasonable efforts to provide services to the child and the child’s parent for the 

purpose of facilitating reunification of the family for a specified period of time. In determining reasonable efforts to be made with 

respect to a minor, and in making reasonable efforts, the minor’s health, safety, and welfare shall be the paramount concern.

When Reasonable Efforts Are Required 

Citation: Ann. Code §§ 62A-4a-203; 78A-6-312

Because the removal of a child from his or her home affects protected, constitutional rights of the parent and has a dramatic, longterm impact on a child, the division shall:

• When possible and appropriate, and without danger to the child’s welfare, make reasonable efforts to prevent or eliminate the 

need for removal of a child from the child’s home prior to placement in substitute care

• Determine whether there is substantial cause to believe that a child has been abused or neglected or is in danger of abuse or 

neglect prior to removing the child from his or her home

• When it is possible and appropriate, make reasonable efforts to make it possible for a child in substitute care to return to his 

or her home

• Take measures in a timely manner to place the child in accordance with the permanency plan and complete whatever steps 

are necessary to finalize the permanent placement of the child if continuation of reasonable efforts to reunify a minor is 

determined to be inconsistent with the final permanency plan for the child

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 78A-6-312

Reasonable efforts are not required if the court finds by clear and convincing evidence that any of the following circumstances exist:

• The parent’s whereabouts is unknown.

• The parent suffers from a severe mental illness that renders the parent incapable of using reunification services.

• The child previously was adjudicated as an abused child, was removed from the home, was returned home, and is being 

removed due to additional abuse.
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• The parent:

» Caused the death of another minor through abuse or neglect

» Committed, attempted, or conspired to commit murder or manslaughter of a child

» Committed sexual abuse against the child

» Is a registered sex offender or required to register as a sex offender

» Has caused, is identified as a suspect, or is being prosecuted for intentionally, knowingly, or recklessly causing the death of 

another parent of the child

• The child suffered severe abuse by the parent or by a person known by the parent, and the parent knew or reasonably should 

have known about the abused.

• The parent has severely abused the child.

• The parent’s rights were terminated with regard to any other child.

• The child was removed from his or her home on at least two previous occasions, and reunification services were offered or 

provided to the family at those times.

• The parent abandoned the child for 6 months or longer.

• The parent permitted the child to reside, permanently or temporarily, where the parent knew or should have known that a 

clandestine laboratory operation was located.

• With respect to the child’s birth mother, the child has fetal alcohol syndrome, fetal alcohol spectrum disorder, or was exposed 

prenatally to an illegal or prescription drug, unless the mother completes an approved substance abuse treatment program.

• Other circumstances preclude reunification efforts or services.

Vermont

What Are Reasonable Efforts? 

Citation: Ann. Stat. Tit. 33, § 5102

The term ‘reasonable efforts’ means the exercise of due diligence by the Department for Children and Families to use appropriate 

and available services to prevent unnecessary removal of the child from his or her home or to finalize a permanency plan.

When Reasonable Efforts Are Required 

Citation: Ann. Stat. Tit. 33, §§ 5102; 5321

Reasonable efforts must be made to prevent unnecessary removal of the child from the home. In cases involving a child who has 

been removed from the home, reasonable efforts must be made to finalize the permanency plan for the child. Reasonable efforts to 

finalize a permanency plan and may consist of:

• When the permanency plan for the child is reunification, efforts to reunify the child and family following the child’s removal 

from the home

• When the permanency plan for the child does not include reunification, efforts to arrange and finalize an alternate permanent 

living arrangement for the child

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. Tit. 33, § 5102

When making the reasonable efforts determination, the court may find that no services were appropriate or reasonable considering 

the circumstances. If the court makes written findings that aggravated circumstances are present, the court may make but is not 

required to make written findings as to whether reasonable efforts were made to prevent removal of the child from the home. 

Aggravated circumstances include:

• The parent has subjected a child to abandonment, torture, chronic abuse, or sexual abuse.

• The parent has been convicted of murder or manslaughter of a child.

• The parent has been convicted of a felony crime that results in serious bodily injury to the child or another child of the parent.

• The parental rights of the parent with respect to a sibling have been terminated. 
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Virgin Islands

What Are Reasonable Efforts? 

Citation: Ann. Code Tit. 5, § 2550

The term ‘reasonable efforts’ means the exercise of due diligence and care by the Department of Human Services to utilize all available 

services related to meeting the needs of the child and the family and to assist the parents in remedying the circumstances and 

conditions that led to the placement of the child and in reinforcing the family structure, including:

• Consultation and cooperation with the parent in developing a plan for appropriate services

• Providing services to the family that have been agreed upon in order to further the goal of family reunification

• Informing the parent at appropriate intervals of the child’s progress, development, and health

• Facilitating appropriate visitation

When Reasonable Efforts Are Required

This issue is not addressed in the statutes reviewed. 

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code Tit. 5, § 2550

Reasonable efforts are not required if the court finds that any of the following grounds for termination of parental rights exists:

• The parent has abandoned the child.

• The parent has not complied with the department’s reasonable efforts to achieve reunification.

• The child has been removed from the home for more than 6 months, and:

» The conditions that led to the child’s removal still persist.

» There is little likelihood that the conditions that led to the child’s removal will be remedied within the next 18 months.

• The parent has been convicted of aggravated child abuse or neglect, as defined in tit. 14, § 506, against the child, a sibling, halfsibling, or any other child residing temporarily or permanently in the home of the parent.

• The parent has been convicted of the intentional death of the child’s other parent.

• The parent is unable to discharge parental duties due to:

» Emotional illness, mental illness, or mental deficiency

» Habitual abuse or addiction to intoxicating liquors, narcotics, or other dangerous drugs

• The parent has failed to manifest an ability and willingness to assume custody of the child.

• Placing the child in the parent’s custody would pose a risk of substantial harm to the physical or psychological welfare of the child.

• The parent has relinquished the parent’s rights or consented to the child’s adoption.

• The parent has:

» Committed murder or manslaughter of any sibling or half-sibling of the child

» Aided, abetted, attempted, or conspired to commit such murder or a voluntary manslaughter

» Committed a felony assault that resulted in serious bodily injury to the child or any sibling or half-sibling

• The parent has on two or more occasions abused or neglected any child.

• Within 18 months after a child’s return from an out-of-home placement, the child is removed from the parent’s custody and 

placed in care outside the home a second time.

Virginia

What Are Reasonable Efforts? 

Citation: Ann. Code § 16.1-281

Reasonable efforts include programs, care, services, and other support that will be offered to the child and his or her parents that will 

lead to the return of the child to his or her parents within the shortest practicable time. 

When Reasonable Efforts Are Required 

Citation: Ann. Code §§ 16.1-278.4; 16.1-282.1(C)

Reasonable efforts must be made to prevent removal of the child from his or her home, unless continued placement in the home would 

be contrary to the welfare of the child.
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If the child has been removed from the home, reasonable efforts must be made:

• To reunite the child with the child’s family, if returning home is the permanent goal for the child

• To achieve the permanent goal identified in the case plan, if the goal is other than returning the child home

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 16.1-281

Reasonable efforts to reunite the child with a parent are not required if the court finds that:

• The parental rights of the parent regarding a sibling of the child have previously been involuntarily terminated.

• The parent has been convicted of murder or voluntary manslaughter, or a felony attempt, conspiracy, or solicitation to commit 

any such offense, and the victim of the offense was a child of the parent, a child with whom the parent resided at the time the 

offense occurred, or the other parent of the child.

• The parent has been convicted of felony assault resulting in serious bodily injury, felony bodily wounding resulting in serious 

bodily injury, or felony sexual assault, and the victim of the offense was a child of the parent or a child with whom the parent 

resided at the time of such offense.

• Based on clear and convincing evidence, the parent has subjected any child to aggravated circumstances.

• The parent has abandoned a child.

Aggravated circumstances include torture, chronic or severe abuse, or chronic or severe sexual abuse, if the victim of such conduct 

was a child of the parent or child with whom the parent resided at the time such conduct occurred. Aggravated circumstances 

also include failure to protect the child from such conduct, if the conduct or failure to protect demonstrates a wanton or depraved 

indifference to human life, or has resulted in the death of the child or in serious bodily injury to the child. 

Washington

What Are Reasonable Efforts? 

Citation: Rev. Code §§ 13.34.025; 13.34.130

The Department of Social and Health Services shall coordinate within the administrations of the department and with contracted 

service providers, including supervising agencies, to ensure that parents in dependency proceedings receive priority access 

to remedial services recommended by the department or supervising agency in its social study or ordered by the court for the 

purpose of correcting any parental deficiencies identified in the dependency proceeding that are capable of being corrected in the 

foreseeable future. Services also may be provided to caregivers other than the parents as identified in § 13.34.138.

For purposes of this chapter, remedial services are those services defined in the Federal Adoption and Safe Families Act as timelimited family reunification services. Remedial services include:

• Individual, group, and family counseling

• Substance abuse treatment services

• Mental health services

• Assistance to address domestic violence

• Services designed to provide temporary child care and therapeutic services for families

• Transportation to or from any of the above services and activities

Reasonable efforts include specific services, such as housing assistance, that are provided to the child and the child’s parent, 

guardian, or legal custodian, and preventive services that are offered or provided to prevent the need for out-of-home placement. 

When Reasonable Efforts Are Required 

Citation: Rev. Code §§ 13.34.110; 13.34.130

Reasonable efforts are required to prevent or eliminate the need for removal of the child from the child’s home and to make it 

possible for the child to return home.

An order for out-of-home placement may be made only if the court finds that reasonable efforts have been made to prevent or 

eliminate the need for removal of the child from the child’s home and to make it possible for the child to return home, specifying the 

services (including housing assistance) that have been provided to the child and the child’s parent, guardian, or legal custodian, and 

that preventive services have been offered or provided to the child and the child’s parent, guardian, or custodian, and the services 

have failed to prevent the need for out-of-home placement, unless the health, safety, and welfare of the child cannot be protected 

adequately in the home.
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When Reasonable Efforts Are NOT Required 

Citation: Rev. Code § 13.34.132

Reasonable efforts are not required when there are aggravated circumstances. In determining whether aggravated circumstances 

exist by clear, cogent, and convincing evidence, the court shall consider one or more of the following:

• Conviction of the parent of rape, criminal mistreatment, or assault of the child

• Conviction of the parent of murder, manslaughter, or homicide by abuse of the child’s other parent, sibling, or another child

• Conviction of the parent of attempting, soliciting, or conspiring to commit any of the above crimes

• Conviction of the parent of trafficking or promoting commercial sexual abuse of a minor when the victim of the crime is the 

child, the child’s other parent, a sibling of the child, or another child

• A finding by a court that a parent is a sexually violent predator

• Failure of the parent to complete a treatment plan where such failure has resulted in a prior termination of parental rights to 

another child and the parent has failed to effect significant change in the interim

• Abandonment of an infant younger than age 3

• Conviction of the parent of a sex offense or incest when the child is born of the offense

West Virginia

What Are Reasonable Efforts? 

Citation: Ann. Code §§ 49-1-201; 49-1-206

Child abuse and neglect services’ means social services that are directed toward: 

• Protecting and promoting the welfare of children who are abused or neglected 

• Identifying, preventing, and remedying conditions that cause child abuse and neglect 

• Preventing the unnecessary removal of children from their families by identifying family problems and assisting families in 

resolving problems that could lead to a removal of children and a breakup of the family

• In cases in which children have been removed from their families, providing time-limited reunification services to the children 

and the families so as to reunify those children with their families or some portion thereof

• Placing children in suitable adoptive homes when reunifying the children with their families, or some portion thereof, is not 

possible or appropriate

• Assuring the adequate care of children or juveniles who have been placed in the custody of the Department of Health and 

Human Resources or third parties

The term ‘time-limited reunification services’ means individual, group, and family counseling; inpatient, residential, or outpatient 

substance abuse treatment services; mental health services; assistance to address domestic violence; services designed to provide 

temporary child care and therapeutic services for families, including crisis nurseries and transportation to or from those services, 

provided during 15 of the most recent 22 months a child has been in foster care, as determined by the earlier date of the first judicial 

finding that the child is subjected to abuse or neglect or the date that is 60 days after the child is removed from home.

Reasonable efforts are measures taken by the department to provide remedial and reunification services. 

When Reasonable Efforts Are Required 

Citation: Ann. Code § 49-4-604 

Reasonable efforts must be made:

• To preserve the family and to prevent placement

• To eliminate the need for removing the child from the child’s home

• To make it possible for the child to return home safely 

When Reasonable Efforts Are NOT Required 

Citation: Ann. Code § 49-4-602 

The department is not required to make reasonable efforts to preserve the family if the court determines:

• The parent has subjected the child, another child of the parent, or any other child residing in the same household to 

aggravated circumstances, including abandonment, torture, chronic abuse, and sexual abuse.

• The parent has:

» Committed murder or voluntary manslaughter of the child’s other parent, another child of the parent, or any other child 

residing in the same household 
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» Attempted or conspired to commit such a murder or voluntary manslaughter 

» Committed a felonious assault that results in serious bodily injury to the child, the child’s other parent, to another child of 

the parent, or any other child residing in the same household 

» Committed sexual assault or sexual abuse of the child, the child’s other parent, another child of the parent, or any other 

child residing in the same household 

» Has been required by State or Federal law to register with a sex offender registry

• The parental rights of the parent to another child have been terminated involuntarily.

• The parent has habitually abused or is addicted to alcohol, controlled substances, or drugs, to the extent that proper 

parenting skills have been seriously impaired.

• The parent has refused to cooperate in the development of a reasonable family case plan.

• The abusing parent or parents have not responded to rehabilitative efforts designed to reduce or prevent the abuse or 

neglect of the child.

• The parent has abandoned the child.

• The parent has an emotional illness, mental illness, or mental deficiency of such duration or nature as to render such parent 

incapable of exercising proper parenting skills or sufficiently improving the adequacy of such skills.

• The abusing parent has repeatedly or seriously injured the child physically or emotionally, or have sexually abused or sexually 

exploited the child.

• The battered parent’s parenting skills have been seriously impaired, and the person has willfully refused or is presently 

unwilling or unable to cooperate with a reasonable treatment plan.

Wisconsin

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 48.355

Reasonable efforts shall include, but not be limited to:

• A comprehensive assessment of the family’s situation 

• Financial assistance to the family, if applicable

• Provision of services, including in-home support and intensive treatment services, community support services, or specialized 

services for family members with special needs

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 48.355

Reasonable efforts must be made:

• To prevent the removal of the child from the home

• To return the child safely to the child’s home

• To achieve the goal of the child’s permanency plan

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 48.355

Reasonable efforts are not required if the court finds any of the following:

• The parent has subjected the child to aggravated circumstances, including abandonment, torture, chronic abuse, and sexual 

abuse.

• The parent has committed, has aided or abetted the commission of, or has solicited, conspired, or attempted to commit, 

intentional homicide, reckless homicide, or felony murder, and the victim is a child of the parent.

• The parent has committed battery, sexual assault, sexual assault of a child, or physical child abuse that resulted in great or 

substantial bodily harm to the child or another child of the parent.

• The parental rights of the parent to another child have been involuntarily terminated. 

• The parent has relinquished custody of the child when the child was 72 hours old or younger. 
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Wyoming

What Are Reasonable Efforts? 

Citation: Ann. Stat. § 14-3-440

Reasonable efforts require services to the family that are accessible, available, and appropriate. 

When Reasonable Efforts Are Required 

Citation: Ann. Stat. § 14-3-440

Reasonable efforts must be made:

• Prior to placement of the child outside the home to prevent or eliminate the need for removing the child from the child’s home

• To make it possible for the child to return home safely

• If continuation of reasonable efforts is determined to be inconsistent with the permanency plan for the child, to complete the 

steps necessary to finalize the permanent placement of the child

When Reasonable Efforts Are NOT Required 

Citation: Ann. Stat. § 14-2-309(b)-(c)

Reasonable efforts to reunify the family are not required when the parent has been convicted of any of the following crimes:

• Murder or voluntary manslaughter of another child of the parent or aiding and abetting, attempting, conspiring to commit, or 

soliciting such a crime

• Commission of a felony assault that results in serious bodily injury to a child of the parent

Notwithstanding any other provision of this section, evidence that reasonable efforts have been made to preserve and reunify the 

family is not required in any case in which the court determines, by clear and convincing evidence, any one or more of the following:

• The parental rights of the parent to any other child have been terminated involuntarily.

• The parent abandoned, chronically abused, tortured, or sexually abused the child.

• The parent has been convicted of committing one or more of the following crimes against the child or another child of that 

parent:

» Sexual assault under §§ 6-2-302 through 6-2-304

» Sexual battery under § 6-2-313

» Sexual abuse of a minor under §§ 6-2-314 through 6-2-317

• The parent is required to register as a sex offender pursuant to § 7-19-302, if the offense involved the child or another child of 

that parent. This shall not apply if the parent is only required to register for conviction under § 6-2-201.

• Other aggravating circumstances exist indicating that there is little likelihood that services to the family will result in successful 

reunification.