Michigan Compiled Laws

Mich. Comp. Laws § 712A.18f (2026)

Report; preparation and contents of case service plan; order of disposition; updating and revising case service plan; rules; review by child's physician in case of abuse and neglect; testimony.

✓ current as of July 2026

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PROBATE CODE OF 1939

Act 288 of 1939

712A.18f Report; preparation and contents of case service plan; order of disposition; updating and revising case service plan; rules; review by child's physician in case of abuse and neglect; testimony.

Sec. 18f.

(1) If, in a proceeding under section 2(b) of this chapter, an agency advises the court against placing a child in the custody of the child's parent, guardian, or custodian, the agency shall report in writing to the court what efforts were made to prevent the child's removal from his or her home or the efforts made to rectify the conditions that caused the child's removal from his or her home. The report shall include all of the following:

(a) If services were provided to the child and his or her parent, guardian, or custodian, the services, including in-home services, that were provided.

(b) If services were not provided to the child and his or her parent, guardian, or custodian, the reasons why services were not provided.

(d) Likely harm to the child if the child were to be returned to his or her parent, guardian, or custodian.

(2) Before the court enters an order of disposition in a proceeding under section 2(b) of this chapter, the agency shall prepare a case service plan that shall be available to the court and all the parties to the proceeding.

(3) The case service plan shall provide for placing the child in the most family-like setting available and in as close proximity to the child's parents' home as is consistent with the child's best interests and special needs. The case service plan shall include, but is not limited to, the following:

(a) The type of home or institution in which the child is to be placed and the reasons for the selected placement.

(b) Efforts to be made by the child's parent to enable the child to return to his or her home.

(d) Schedule of services to be provided to the parent, child, and if the child is to be placed in foster care, the foster parent, to facilitate the child's return to his or her home or to facilitate the child's permanent placement.

(e) Except as otherwise provided in this subdivision, unless parenting time, even if supervised, would be harmful to the child as determined by the court under section 13a of this chapter or otherwise, a schedule for regular and frequent parenting time between the child and his or her parent, which shall not be less than once every 7 days.

(f) Efforts to be made by the supervising agency to provide frequent in-person visitation or other ongoing interaction between siblings unless the court determines under section 13a of this chapter that sibling visitation or contact will not be beneficial to 1 or more of the siblings.

(g) Conditions that would limit or preclude placement or parenting time with a parent who is required by court order to register under the sex offenders registration act.

(4) Before the court enters an order of disposition, the court shall consider the case service plan; any written or oral information offered concerning the child from the child's parent, guardian, custodian, foster parent, child caring institution, relative with whom the child is placed, lawyer-guardian ad litem, attorney, or guardian ad litem; and any other evidence offered, including the appropriateness of parenting time, which information or evidence bears on the disposition. The order of disposition shall state whether reasonable efforts have been made to prevent the child's removal from his or her home or to rectify the conditions that caused the child's removal from his or her home. The court may order compliance with all or any part of the case service plan as the court considers necessary.

(5) If a child continues in placement outside of the child's home, the case service plan shall be updated and revised at 90-day intervals as required by the rules promulgated under 1973 PA 116, MCL 722.111 to 722.128. The agency shall consult with the foster parents when it updates and revises the case service plan, and shall attach a statement summarizing the information received from the foster parents to the updated and revised case service plan. Updated and revised case service plans shall be available to the court and all the parties to the proceeding. Within 10 days after receipt of a written request, the agency shall provide the person who is providing the foster care with the information itemized in section 13a(17) of this chapter.

(6) To ensure that the case service plan addresses the child's medical needs in relation to abuse and neglect, the department shall review a child's case with the child's attending physician of record during a hospitalization or with the child's primary care physician, but only if a physician has diagnosed the child's abuse or neglect as involving 1 or more of the following:

(a) Failure to thrive.

(b) Munchausen syndrome by proxy.

(d) A bone fracture that is diagnosed as being the result of abuse or neglect.

(e) Drug exposure.

(7) If a child is placed outside of his or her home and the department is required to review the child's case with a physician under subsection (6), then in a judicial proceeding to determine if the child is to be returned to his or her home, the court must allow the child's attending physician of record during a hospitalization or the child's primary care physician to testify regarding the case service plan. The court shall notify each physician of the hearing's time and place.

History: Add. 1988, Act 224, Eff. Apr. 1, 1989 ;-- Am. 1994, Act 264, Eff. Jan. 1, 1995 ;-- Am. 1996, Act 16, Eff. June 1, 1996 ;-- Am. 1997, Act 163, Eff. Mar. 31, 1998 ;-- Am. 1998, Act 479, Eff. Mar. 1, 1999 ;-- Am. 1998, Act 480, Eff. Mar. 1, 1999 ;-- Am. 1999, Act 25, Imd. Eff. May 18, 1999 ;-- Am. 2012, Act 115, Imd. Eff. May 1, 2012 ;-- Am. 2016, Act 191, Eff. Sept. 19, 2016

PopularName Notes:

Probate Code

PopularName Notes:

Juvenile Code

AdminRule Notes:

R 400.6101 et seq. of the Michigan Administrative Code.

Notes of Decisions

Cited in 247 cases (127 in the last 5 years), 1989–2026 · leading case: In Re Rood, 763 N.W.2d 587 (Mich. 2009).

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In Re Rood, 763 N.W.2d 587 (Mich. 2009). · cites it 21× “[4] See MCL 712A.18f. [5] There are situations in which the DHS is not required to provide services to the parent and may seek termination at the initial dispositional hearing, including "[a]bandonment of a young child.”

In re Sanders, 852 N.W.2d 524 (Mich. 2014). · cites it 12× “14 See MCL 712A.18f. The procedures afforded parents during the dispositional phase are not related to the allegations of unfitness because the question a court is answering at a dispositional hearing assumes a previous finding of parental unfitness.”

In Re Hrc, 781 N.W.2d 105 (Mich. Ct. App. 2009). · cites it 9× “*462 V REUNIFICATION EFFORTS Respondents next argue that their due process rights were violated between the time that respondents entered their pleas and the second termination petition was filed because no case service plan was developed pursuant to MCL 712A.18f. We disagree.…”

In Re Mason, 782 N.W.2d 747 (Mich. 2010). · cites it 5× “19a(5) provides for the court's consideration of a parent's failure to comply with a service plan as follows: [T]he court shall view the failure of the parent to substantially comply with the terms and conditions of the case service plan prepared under [MCL 712A.18f] as evidence…”

In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). · cites it 5× “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”

In Re Amb, 640 N.W.2d 262 (Mich. Ct. App. 2002). · cites it 4× “Unlike MCL 712A.18f, which is tied to the dispositional phase of a child protective proceeding, MCL 722.”

In Re Mary G., 59 Cal. Rptr. 3d 703 (Cal. Ct. App. 2007). · cites it 3× “" (Mich.Comp.Laws, § 712A.18f, subds.(2) & (4).”

In re Hicks, 890 N.W.2d 696 (Mich. Ct. App. 2016). · cites it 3× “See In re Mason, 486 Mich 142, 156 ; 782 NW2d 747 (2010); MCL 712A.18f(3). The need to make “reasonable efforts” stems from federal law.”

People v. Tennyson, 790 N.W.2d 354 (Mich. 2010). · cites it 2× “” MCL 712A.18f(3)(d); see also MCL 712A.13a(8)(a).”

In re Deng, 887 N.W.2d 445 (Mich. Ct. App. 2016). · cites it 3× “In determining what measures to take with respect to a child, the court must consider the case service plan prepared by Michigan’s Department of Health and Human Services (DHHS) as well as information provided by various individuals, including the child’s parent.”

Hunter v. Hunter, 771 N.W.2d 694 (Mich. 2009). · cites it 2× “MCL 712A.18f. The court generally reviews the case within 182 days of the child's removal and every 91 days thereafter.”

In re Terry, 610 N.W.2d 563 (Mich. Ct. App. 2000). · cites it 2× “Under MCL 712A.18f(4); MSA 27.3178(598.180(4), before *26 entering an order of disposition, the court must determine whether the fia has made “reasonable efforts” to rectify the conditions that led to its involvement in the case.”

Show all 247 citing cases →

— Mich. Comp. Laws § 712A.18f(1) — 38 cases

In Re Rood, 763 N.W.2d 587 (Mich. 2009). “[4] See MCL 712A.18f. [5] There are situations in which the DHS is not required to provide services to the parent and may seek termination at the initial dispositional hearing, including "[a]bandonment of a young child.”

In Re Fried, 702 N.W.2d 192 (Mich. Ct. App. 2005).

in Re a C Hawkins Minor (Mich. Ct. App. 2016).

in Re burkhart/odil Minors (Mich. Ct. App. 2019).

in Re M Arendt-Walker Minor (Mich. Ct. App. 2016).

— Mich. Comp. Laws § 712A.18f(1)(b) — 12 cases

In Re Terry, 610 N.W.2d 563 (Mich. Ct. App. 2000).

In Re E E Kirby Minor (Mich. Ct. App. 2023).

in Re R J B B Higgs III Minor (Mich. Ct. App. 2016).

in Re Jones Minors (Mich. Ct. App. 2017).

— Mich. Comp. Laws § 712A.18f(1)(c) — 1 case

in Re Sanders Minors (Mich. 2014).

— Mich. Comp. Laws § 712A.18f(2) — 14 cases

In re Sanders, 852 N.W.2d 524 (Mich. 2014). “14 See MCL 712A.18f. The procedures afforded parents during the dispositional phase are not related to the allegations of unfitness because the question a court is answering at a dispositional hearing assumes a previous finding of parental unfitness.”

In Re Hulbert, 465 N.W.2d 36 (Mich. Ct. App. 1990).

In Re alexander/lee/cantu/thomas Minors (Mich. Ct. App. 2026).

in Re Hill Minors (Mich. Ct. App. 2016).

— Mich. Comp. Laws § 712A.18f(2)(e) — 1 case

In Re Nelson Minors (Mich. Ct. App. 2026).

— Mich. Comp. Laws § 712A.18f(3) — 13 cases

In re Hicks, 890 N.W.2d 696 (Mich. Ct. App. 2016). “See In re Mason, 486 Mich 142, 156 ; 782 NW2d 747 (2010); MCL 712A.18f(3). The need to make “reasonable efforts” stems from federal law.”

20231121_C365616_32_365616.Opn.Pdf (Mich. Ct. App. 2023).

in Re hicks/brown Minors (Mich. Ct. App. 2016).

— Mich. Comp. Laws § 712A.18f(3)(b) — 87 cases

In Re B J Phillips (Mich. Ct. App. 2023).

In Re K a Kazmierczak Minor (Mich. Ct. App. 2024).

in Re hicks/brown Minors (Mich. 2017).

in Re Cary Minors (Mich. Ct. App. 2018).

— Mich. Comp. Laws § 712A.18f(3)(c) — 10 cases

In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”

In Re Jacobs, 444 N.W.2d 789 (Mich. 1989).

Dep't of Soc. Servs. v. Smith, 433 Mich. 24 (Mich. 1989).

in Re freeman/taite Minors (Mich. Ct. App. 2020).

In Re a K Dixon Minor (Mich. Ct. App. 2023).

— Mich. Comp. Laws § 712A.18f(3)(d) — 70 cases

In Re Mason, 782 N.W.2d 747 (Mich. 2010). “19a(5) provides for the court's consideration of a parent's failure to comply with a service plan as follows: [T]he court shall view the failure of the parent to substantially comply with the terms and conditions of the case service plan prepared under [MCL 712A.18f] as evidence…”

People v. Tennyson, 790 N.W.2d 354 (Mich. 2010). “” MCL 712A.18f(3)(d); see also MCL 712A.13a(8)(a).”

In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”

In re DMK, 796 N.W.2d 129 (Mich. Ct. App. 2010).

— Mich. Comp. Laws § 712A.18f(3)(e) — 13 cases

In Re Hrc, 781 N.W.2d 105 (Mich. Ct. App. 2009). “*462 V REUNIFICATION EFFORTS Respondents next argue that their due process rights were violated between the time that respondents entered their pleas and the second termination petition was filed because no case service plan was developed pursuant to MCL 712A.18f. We disagree.…”

In re Laster, 845 N.W.2d 540 (Mich. Ct. App. 2013).

20221215_C362073_34_362073.Opn.Pdf (Mich. Ct. App. 2022).

in Re Z a Scott Minor (Mich. Ct. App. 2019).

In Re Carpenter Minors (Mich. Ct. App. 2025).

— Mich. Comp. Laws § 712A.18f(4) — 36 cases

In Re Amb, 640 N.W.2d 262 (Mich. Ct. App. 2002). “Unlike MCL 712A.18f, which is tied to the dispositional phase of a child protective proceeding, MCL 722.”

In re Deng, 887 N.W.2d 445 (Mich. Ct. App. 2016). “In determining what measures to take with respect to a child, the court must consider the case service plan prepared by Michigan’s Department of Health and Human Services (DHHS) as well as information provided by various individuals, including the child’s parent.”

In re Hicks, 890 N.W.2d 696 (Mich. Ct. App. 2016). “See In re Mason, 486 Mich 142, 156 ; 782 NW2d 747 (2010); MCL 712A.18f(3). The need to make “reasonable efforts” stems from federal law.”

In re Terry, 610 N.W.2d 563 (Mich. Ct. App. 2000). “Under MCL 712A.18f(4); MSA 27.3178(598.180(4), before *26 entering an order of disposition, the court must determine whether the fia has made “reasonable efforts” to rectify the conditions that led to its involvement in the case.”

— Mich. Comp. Laws § 712A.18f(5) — 16 cases

In Re C J Taylor Minor (Mich. Ct. App. 2025).

In Re Underwood Minors (Mich. Ct. App. 2025).

In Re K a M Ogletree Minor (Mich. Ct. App. 2025).

— Mich. Comp. Laws § 712A.18f(c) — 1 case

in Re L D Rippy Minor (Mich. Ct. App. 2019).

— Mich. Comp. Laws § 712A.18f(l) — 3 cases

In re Hicks, 890 N.W.2d 696 (Mich. Ct. App. 2016). “See In re Mason, 486 Mich 142, 156 ; 782 NW2d 747 (2010); MCL 712A.18f(3). The need to make “reasonable efforts” stems from federal law.”

— Mich. Comp. Laws § 712A.18f(l)(b) — 2 cases

In Re Le, 747 N.W.2d 883 (Mich. Ct. App. 2008). “18f(3)(c) requires that the case service plan identify the efforts to be made by the agency to return “the child to his or her home.”

— Mich. Comp. Laws § 712A.18f(l)(c) — 1 case

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