Iowa Code

Iowa Code § 232.102A (2026)

Reasonable efforts

✓ current as of July 2026
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1. For the purposes of this subchapter: a. “Reasonable efforts” means the efforts made to preserve and unify a family prior to the out-of-home placement of a child in foster care or to eliminate the need for removal of the child or make it possible for the child to safely return to the family’s home. Reasonable efforts include but are not limited to giving consideration, if appropriate, to interstate placement of a child in the permanency planning decisions involving the child and giving consideration to in-state and out-of-state placement options at a permanency hearing and when using concurrent planning. If returning the child to the family’s home is not appropriate or not possible, reasonable efforts shall include the efforts made in a timely manner to finalize a permanency plan for the child. A child’s health and safety shall be the paramount concern in making reasonable efforts. 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. In determining whether reasonable efforts have been made, the court shall consider all of the following: (1) The type, duration, and intensity of services or support offered or provided to the child and the child’s family. If family-centered services were not provided, the court record shall

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Tue Dec 09 22:21:33 2025 Iowa Code 2026, Chapter 232 (92, 1) §232.102A, JUVENILE JUSTICE 80\n\nenumerate the reasons the services were not provided, including but not limited to whether the services were not available, not accepted by the child’s family, judged to be unable to protect the child and the child’s family during the time the services would have been provided, judged to be unlikely to be successful in resolving the problems which would lead to removal of the child, or other services were found to be more appropriate. (2) The relative risk to the child of remaining in the child’s home versus removal of the child. b. “Family-centered services” means services and other support intended to safely maintain a child with the child’s family or with an adult relative, to safely and in a timely manner return a child to the home of the child’s parent or relative, or to promote 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 include services 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 and services 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. 2. Family interactions shall continue regardless of a parent’s failure to comply with the requirements of a court order or the department unless a court finds that substantial evidence exists that the family interactions, whether supervised or unsupervised, would pose a serious risk of physical or emotional harm to the child. 3. The performance of reasonable efforts to place a child for adoption or with a guardian may be made concurrently with making reasonable efforts. 4. If the court determines by clear and convincing evidence that aggravated circumstances exist supported by written findings of fact based upon evidence in the record, the court may waive the requirement for making reasonable efforts. The existence of aggravated circumstances is indicated by any of the following: a. The parent has abandoned the child. b. The court finds the circumstances described in section 232.116, subsection 1, paragraph “i”, are applicable to the child. c. The parent’s parental rights have been terminated under section 232.116 or involuntarily terminated by an order of a court of competent jurisdiction in another state with respect to another child who is a member of the same family, and there is clear and convincing evidence to show that the offer or receipt of services would not be likely within a reasonable period of time to correct the conditions which led to the child’s removal. d. The parent has been convicted of the murder of another child. e. The parent has been convicted of the voluntary manslaughter of another child. f. The parent has been convicted of aiding or abetting, attempting, conspiring in, or soliciting the commission of the murder or voluntary manslaughter of another child. g. The parent has been convicted of a felony assault which resulted in serious bodily injury to the child or another child. 5. Prior services the state provided to the family shall not be considered in making a determination as to whether a waiver of reasonable efforts is appropriate. 2022 Acts, ch 1098, §49; 2025 Acts, ch 23, §1; 2025 Acts, ch 86, §61 Referred to in §232.2, 232.101A, 232.104, 232.111, 232B.5, 233.2, 234.6 Subsection 2 amended Subsection 3 amended

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Notes of Decisions
Cited in 16 cases (16 in the last 5 years), 2023–2026 · leading case: In the Interest of R.D. & A.D., Minor Child. (Iowa Ct. App. 2023).
In the Interest of R.D. & A.D., Minor Child. (Iowa Ct. App. 2023). · cites it 16× “As part of their reasonable-efforts challenge, the mother and father challenge the constitutionality of Iowa Code section 232.102A(2) (Supp. 2022), which provides, “Family interactions shall continue regardless of a parent’s failure to comply with the requirements of a court…”
In the Interest of M.H., Minor Child (Iowa Ct. App. 2024). · cites it 12× “Instead, the mother contends the waiver was unwarranted because “there was not enough time to determine whether” the second condition was met, while the father simply argues 3 The enactment of section 232.102A took effect on July 1, 2022.”
In the Interest of A.H., B.H., B.H., B.H., E.H., & K.H., Minor Child. (Iowa Ct. App. 2025). · cites it 10× “” Yet in another paragraph of the ruling, the court found that it did “not have enough information currently” to determine whether family interactions would be detrimental to the children, as required by section 232.102A(2). The court then ordered that visitation between the…”
In re the Interest of L.P, Minor Child (Iowa 2026). · cites it 10× “to safely return to Mom, it could have waived the reasonable efforts requirement sua sponte or upon motion from a party in the case under Iowa Code section 232.102A. This section provides, “If the court determines by clear and convincing evidence that aggravated circumstances…”
In the Interest of R.B. & S.B., Minor Child. (Iowa Ct. App. 2026). · cites it 10× “under Iowa Code section 232.102A(2) (2025). Besides contesting the suspension of family interactions, Kathrine contends that the court erred in denying her motion for reasonable efforts.”
In the Interest of D.C., T.C., T.C., T.C., & T.J., Minor Child. (Iowa Ct. App. 2024). · cites it 4× “Ten days later, the mother filed a “motion for reasonable efforts” under Iowa Code section 232.102A. She asked for more “face-to-face interactions with her children supervised by family members.”
In the Interest of J.B. & J.B., Jr., Minor Child. (Iowa Ct. App. 2026). · cites it 4× “As part of the adjudicatory order and subsequent dispositional order, the juvenile court suspended visits between the mother and the children pursuant to Iowa Code section 232.102A(2) (2025), finding interactions between the mother and children would pose a serious risk of…”
In the Interest of A.B.-G., K.B.-G., & K.B.-G., Minor Child. (Iowa Ct. App. 2023). · cites it 2× “We do not read Elaina’s mention of video visits as raising a reasonable-efforts challenge under section 232.102A. So we do not address that issue.”
In the Interest of F.W., Minor Child (Iowa Ct. App. 2024). · cites it 2× “§ 232.102A(1)(a) (defining reasonable efforts).”
In the Interest of A.C., B.C., & P.C., Minor Child. (Iowa Ct. App. 2024). · cites it 2× “The father and the State point to Iowa Code section 232.102A, which requires HHS to make reasonable efforts toward reunification.”
In the Interest of J.E., Minor Child (Iowa Ct. App. 2025). · cites it 2× “If the mother cannot handle unsupervised visits, she certainly cannot handle having the child returned to her at this time. Clear and convincing evidence has been presented showing the child cannot be returned to the mother at the present time.”
In the Interest of B.H., Minor Child (Iowa Ct. App. 2025). · cites it 2× “And we do not read section 232.102A(2) so rigidly as to invalidate any visitation order that lacks the specific word “detrimental.”
— Iowa Code § 232.102A(1)(a) — 6 cases
In the Interest of D.C., T.C., T.C., T.C., & T.J., Minor Child. (Iowa Ct. App. 2024). “Ten days later, the mother filed a “motion for reasonable efforts” under Iowa Code section 232.102A. She asked for more “face-to-face interactions with her children supervised by family members.”
In the Interest of J.E., Minor Child (Iowa Ct. App. 2025). “If the mother cannot handle unsupervised visits, she certainly cannot handle having the child returned to her at this time. Clear and convincing evidence has been presented showing the child cannot be returned to the mother at the present time.”
In re the Interest of L.P, Minor Child (Iowa 2026). “to safely return to Mom, it could have waived the reasonable efforts requirement sua sponte or upon motion from a party in the case under Iowa Code section 232.102A. This section provides, “If the court determines by clear and convincing evidence that aggravated circumstances…”
In the Interest of E.W., Minor Child (Iowa Ct. App. 2023).
— Iowa Code § 232.102A(2) — 5 cases
In the Interest of R.D. & A.D., Minor Child. (Iowa Ct. App. 2023). “As part of their reasonable-efforts challenge, the mother and father challenge the constitutionality of Iowa Code section 232.102A(2) (Supp. 2022), which provides, “Family interactions shall continue regardless of a parent’s failure to comply with the requirements of a court…”
In the Interest of A.H., B.H., B.H., B.H., E.H., & K.H., Minor Child. (Iowa Ct. App. 2025). “” Yet in another paragraph of the ruling, the court found that it did “not have enough information currently” to determine whether family interactions would be detrimental to the children, as required by section 232.102A(2). The court then ordered that visitation between the…”
In the Interest of R.B. & S.B., Minor Child. (Iowa Ct. App. 2026). “under Iowa Code section 232.102A(2) (2025). Besides contesting the suspension of family interactions, Kathrine contends that the court erred in denying her motion for reasonable efforts.”
In the Interest of J.B. & J.B., Jr., Minor Child. (Iowa Ct. App. 2026). “As part of the adjudicatory order and subsequent dispositional order, the juvenile court suspended visits between the mother and the children pursuant to Iowa Code section 232.102A(2) (2025), finding interactions between the mother and children would pose a serious risk of…”
In the Interest of B.H., Minor Child (Iowa Ct. App. 2025). “And we do not read section 232.102A(2) so rigidly as to invalidate any visitation order that lacks the specific word “detrimental.”
— Iowa Code § 232.102A(3) — 1 case
In the Interest of A.S., Minor Child (Iowa Ct. App. 2025).
— Iowa Code § 232.102A(4) — 1 case
In re the Interest of L.P, Minor Child (Iowa 2026). “to safely return to Mom, it could have waived the reasonable efforts requirement sua sponte or upon motion from a party in the case under Iowa Code section 232.102A. This section provides, “If the court determines by clear and convincing evidence that aggravated circumstances…”
— Iowa Code § 232.102A(4)(a) — 2 cases
In re the Interest of L.P, Minor Child (Iowa 2026). “to safely return to Mom, it could have waived the reasonable efforts requirement sua sponte or upon motion from a party in the case under Iowa Code section 232.102A. This section provides, “If the court determines by clear and convincing evidence that aggravated circumstances…”
In the Interest of F.W., Minor Child (Iowa Ct. App. 2024). “§ 232.102A(1)(a) (defining reasonable efforts).”
— Iowa Code § 232.102A(4)(c) — 1 case
In the Interest of M.H., Minor Child (Iowa Ct. App. 2024). “Instead, the mother contends the waiver was unwarranted because “there was not enough time to determine whether” the second condition was met, while the father simply argues 3 The enactment of section 232.102A took effect on July 1, 2022.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.