DEE WILSON CONSULTING

(Originally published July 2024)

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The following discussion of six countries’ (Denmark, Finland, Norway, Sweden, England and Germany) child protection systems is based several chapters of The Oxford Handbook of Child Protection Systems (2023), edited by Jill Duerr Berrick, Neil Gilbert and Marit Skivenes. This book contains descriptions and analyses of child protection systems in 50 countries around the world, along with an introductory chapter and summary chapter which articulate major themes, including a typology, i.e., a classification system for understanding nations’ child protection systems:

 

1. Child exploitation protective systems

2. Child deprivation protective systems

3. Child maltreatment protective systems

4. Child well-being protective systems

5. Child rights protective systems

 

This typology builds on an older typology developed by Gilbert (2012) for classifying high income countries’ child welfare systems: a) risk oriented systems, b) family services systems and, c) children’s rights systems. Scandinavian countries are generally classified as child rights systems in which children are deemed to have rights independent of their parents and extended families, but which organize their service delivery systems on family service principles to promote child well-being. Germany is viewed as a family services systems which incorporates some child rights principles. England and the U.S. are classified as child maltreatment risk-oriented systems which set a high  threshold for state intrusion in family life, make limited investments in prevention/early intervention services, and have a policy preference for legal structure when a child enters foster care.   

 

The editors and several authors acknowledge that these typologies do not do justice to the complexities of child welfare and child protection practice in various countries which have elements of a child maltreatment focus, along with a family services approach emphasizing preventive/early intervention services and a commitment to children’s rights independent of their families. For example:

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• Both Scandinavian countries and Germany have a strong policy preference for voluntary work with families, but also have legal provisions for involuntary services. Denmark, Norway, Finland and Sweden utilize legal structure for 20-25% of foster  placements.   

• Scandinavian countries have among the highest foster care placement rates among high income countries, (approximately 10 per 1000), almost double the rate of foster placement in England and the U.S., due in part to the number of school age youth placed because of behavior problems. In addition, very few foster children in these countries exit care to adoption, leading to higher rates of foster care compared to the U.S. which utilizes adoption to a far greater extent. Foster care provided on a voluntary basis is often viewed as a family support service in Northern European countries.  

• English child welfare law strongly encourages the development of cooperative partnerships with families. The aspiration of child welfare leaders for many years has been to transform English child welfare into a family services system through the provision of prevention/early intervention services. However, budget cuts to human services under Conservative governments have narrowed (rather than broadened) child welfare involvement to the highest risk families. Budgets act as constraints on aspirations for child protection reform in all countries.  

• Neither England or Germany has a mandatory reporting law, unlike all four Scandinavian countries discussed in this commentary which mandate reporting of child abuse and neglect to varying degrees.

• The child rights orientation of Scandinavian countries and Germany does not include a right to adoption or guardianship for children unable to live with parents due to child maltreatment or other reasons. Germany does not have a legal provision for termination of parental rights. The social values of these countries appear to be incompatible with involuntary adoption.  Attempts of some child advocates and policymakers to encourage adoption in extreme circumstances have largely fallen on deaf ears.  

 

Child welfare policies and practices which are either inconsistent or anomalous in child welfare systems classified as “family service,” “child rights” vs. “child maltreatment” reflect the reality that child welfare systems are not developed from blueprints or consistent carefully considered legislation, but develop gradually in response to high profile events, social values, budgetary limits and specific legislation unconcerned with a broader social philosophy. However, two lessons stand out in chapters on Northern European child welfare systems is that child welfare policies and practices: 1) child welfare systems reflect countries’ social values, 2) nevertheless, these systems include policies and practices that do not easily fit with those values.  Child welfare systems both reveal social values and require policymakers and managers to confront challenges that call for an innovative response, i.e. Do Something Different. Social values sometimes change when they cannot be applied without doing demonstrable harm to persons served by various human services systems.    

 

Child welfare systems are part of a larger social welfare system  

 

An outstanding chapter in the Handbook, “Child Protection Systems in Denmark and Norway,” by Hestbaek, et al, discusses a theme often ignored in U.S. discussions of child welfare reform:

 

 “A child protection system is closely correlated to the welfarist norms governing society in general. … An essential characteristic of both countries is that intrusive child protective services run parallel to a broader interventionist welfare state system that intervenes universally at early stages to prevent a multitude of serious harms from occurring over the life span.”

 

The social democracies of Northern Europe, including Germany, have much lower rates of child poverty and less extreme income inequality than England and the U.S., along with social welfare systems that offer a wide range of family support services intended to prevent the need for involuntary child welfare services. Social values in these countries support the use of voluntary work with families when-ever possible, including after involuntary interventions when parents have made positive changes in their parenting skills. Nevertheless, these are societies which support child welfare intervention as needed, and as early as possible before child maltreatment becomes a frequent occurrence in family life.  

 

In family service systems, responsibility for child protection is widely shared among multiple human services agencies. It is hard to imagine the following description of Germany’s approach to child welfare in a description of either the reality or aspirations of U.S. child welfare systems: “(in Germany), child welfare is a communal task.” Compare this ethos to the U.S. where many families in desperate need receive no outreach or services prior to a CPS report, which may result in an investigation of parenting deficiencies absent any offer of concrete help or other services. In addition, understaffed and inadequately funded child welfare agencies often function as a stand alone last resort when children are endangered, and are widely held in low social regard for doing too little or too much, and doing it poorly.  Many U.S. state child welfare systems have been given inadequate resources for decades despite having the lion’s share of responsibility for child protection, and then scapegoated for the deficiencies of the country’s social welfare system considered as a whole.

 

In Scandinavia and Germany, child protection means something more than governmental interventions following reports of alleged child maltreatment. These societies offer universal services to promote child well-being, a broader goal than child safety narrowly defined as lack of child endangerment, a mission statement which increasingly animates U.S. child welfare systems. Furthermore, in family service systems, child safety is a dimension of child well-being, not an alternative version of child protection in which child well-being counts for little or nothing.

 

Examples of family service/children’s rights child welfare systems in Northern Europe suggest that the U.S. child protection system cannot be effectively reformed through a narrow focus on child welfare agencies. Other public agencies, especially public health departments, public mental health services and economic services agencies, need to be strengthened and given a larger role in child protection, both before and following CPS reports. This cannot occur until policymakers place a higher value on developing more effective child welfare systems, and acknowledge their role in setting up child welfare systems for failure.  Multiple human services systems need to be given a larger role in child protection and resourced to participate in collaborations with child welfare agencies, e.g., in responding to chronic neglect and to parent-child conflict.    

 

Involuntary child protection services in Scandinavia and Germany

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Authors of chapters on Denmark and Norway, Finland and Sweden in Oxford Handbook of Child Protection Systems comment on the conflict between the aspiration of policy makers to work with troubled families on a voluntary basis, a social value backed up by considerable financial investments in prevention/early intervention services, and the reality of laws and policies that support involuntary intervention in the lives of families. The authors do not offer an explanation for why aspirations to work with families voluntarily, combined with substantial investments in universal services, have not eliminated or led to a steady reduction in involuntary interventions in family life.  It appears that even in social democracies with generous welfare benefits and a wide range of social services there is a large group of families affected by substance abuse, chronic mental health concerns, domestic violence and/or dire poverty resistant to services of any kind, and who deeply resent interference with their parenting practices.

 

In family services systems, initial assessments of CPS reports are commonly referred to as needs assessment rather than risk assessment, though it is unclear from discussions in the “Handbook” whether this difference in language reflects a meaningful difference in practice.  Social workers in these Scandinavian countries and Germany must meet a child endangerment standard to justify involuntary intervention following a report of alleged maltreatment which can include educational neglect, witnessing of domestic violence or emotional abuse, allegations that might not result in a CPS investigation or assessment in Wahington state. Nevertheless, use of legal structure remains the exception rather than the rule when a child is placed in out-of-home care, even in the case of infants (see below).  In Finland, “it must be shown that necessary care cannot be provided on a voluntary basis” to justify an involuntary intervention, i.e., either an in-home service plan or placement with legal structure.

 

It appears that in Scandinavian countries child welfare social workers are given more discretion in decision making and are held in higher social regard than in the U.S.  However, all is not rosy among child welfare social workers in Scandinavia.  According to the “Handbook” chapter on child welfare in Finland and Sweden, social workers in Finland sometimes leave child welfare jobs due to “moral distress” caused by working with needy families with inadequate resources and engaging in interventions that possibly do more harm than good. Child welfare is a tough challenge around the world regardless of the differences between and among countries’ child welfare systems.

 

Foster care in Northern Europe

 

The demographic profile of foster care populations in Denmark, Norway, Finland, Sweden and Germany is different than in the U.S., i.e., a much higher percentage of school age children and youth, and a smaller percentage of infants and other preschool children. In 2023, more than 90% of foster children in Norway were school age; only 2.4% of foster children were 0-2 (communication from Marit Skivenes).  Nevertheless, in doing research for this commentary I was surprised to learn that infant placement rates in Scandinavian countries varied in recent years from 3.5 to 7.7 per 1000 (Hestbaek, et al, 2020), one-third to two-thirds of the U.S. rate.  I was also surprised to discover that a large percentage of infant placements in Scandinavian countries are voluntary.

 

It is a plausible hypothesis that large differences in the ratio of pre-school to school age children in foster care largely explain the policy preference for court ordered placements in the U.S. vs. the preference for voluntary placements in Norther European countries.  Even in England, approximately half of foster placements are voluntary, though child welfare critics in these countries insist that voluntary agreements with parents may mask coercive pressures. Nevertheless, Scandinavian countries often utilize voluntary agreements with infants and other preschool children, while the U.S. maintains a preference for legal structure when school age children and youth are placed in out-of-home care.  Furthermore, adoption is widely viewed as a positive child welfare outcome in the U.S., but is rarely used in Scandinavian countries and Germany.  There is a stark difference in social attitudes towards adoption between the U.S. and most Northern European countries that cannot be bridged by policy statements developed by prestigious child advocates, scholars and organizations.

 

Scandinavian countries have made a persistent effort in recent years to reduce the percentage of foster children and youth in residential care. These efforts have had widely varying results. Norway has reduced the percentage of foster youth in residential care to 10%, one of the lowest residential care rates in Europe, while 30% of foster youth in Denmark continue to be placed in residential care facilities.  

In Germany, half of children in out-of-home care live in residential care facilities, though most residential care youth were not placed due to child maltreatment, according to the chapter on Germany in the “Handbook.”     

 

Adolescents in these Scandinavian countries have more of a voice in their case plans than in the U.S. A child rights orientation has a big impact in how public agencies work with adolescents in Scandinavian countries, for example adolescents in foster care in some countries can choose to sever contact with their parents.           

 

Summary

 

A comparison of six child welfare systems in Northern Europe with the U.S. child system highlights major differences in social values and social norms that influence the goals of child welfare and how and when to intervene in family life. Child welfare systems in Northern Europe have a broad concept of child protection and are part of welfare systems that make large investments in prevention services. Nevertheless, these countries’ child protection systems have laws and practices for involuntary work with families, have higher rates of     

foster care than the U.S. and England, and struggle to apply their child rights orientation to permanent planning decisions when a child in foster care cannot be reunified with parents.

 

While it is unrealistic to model child welfare reform initiatives in the U.S. on the child welfare systems of social democracies that have different social values and better financed social welfare systems, it is possible to learn some straightforward lessons from family service/child rights systems: a) child protection requires a concern with child well-being, not just child safety; b) effective child protection requires the participation and collaboration of multiple human services agencies, and c) it is possible to work with a large percentage of families on a voluntary basis. Foster care does not always require legal action.  Voluntary foster care placement can sometimes be utilized as a family support service, rather than the first step in a process which may end in termination of parental rights.

 

References

 

Berrick, J.D., Gilbert, N. & Skivenes, M., "Child Protection Systems Around the World," Chapter 1 in The Oxford Handbook of Child protection Systems, (2003) ed., by Berrick, Gilbert and Skivenes, Oxford University Press, Oxford, New York City.

 

Biesel, K. & Kindler, H., “Child Protection and Welfare in Germany,” Chapter 10 in The Oxford Handbook of Child Protection Systems, Oxford University Press, ed. by Berrick, Gilbert and Skivenes, Oxford, New York City.

 

Gilbert, N., “A comparative study of child welfare systems: Abstract orientations and concrete results,” Children and Youth Services Review, vol. 34, 2, March 2012.  

 

Hestbaek, A., Skivenes, M., Falch-Erickson, A., Idamarie, L. & Backe-Hansen, E., “Child Protection Systems in Denmark and Norway, Chapter 6 in The Oxford Handbook of Child Protection Systems, ed. by Berrick, Gilbert and Skivenes, Oxford University Press, Oxford, New York City.     

 

Hestbaek, A., Hojer, I. & Poso, T., “Child welfare removals of infants: Exploring policies and principles for decision-making in Nordic countries,” Children and Youth Services Review, vol. 108, Jan. 2020.           

 

Hojer, I. & Poso, T., “Child Protection in Finland and Sweden,” Chapter 8, in The Oxford Handbook of Child Protection Systems, ed. by Berrick, Gilbert & Skivenes, Oxford University Press, Oxford, New York City.        

 

Thoburn, J., “Child Welfare and Child Protection Services in England,” Chapter 7 in The Oxford Handbook of Child Protection Systems, ed. by Berrick, Gilbert and Skivenes, Oxford University Press, Oxford, New York City.   

 

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©Dee Wilson     

  

deewilson13@aol.com

    

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