Protecting Children, Creating Citizens. Križ, Katrin

family and community services in cases where risk to the child is considered low or moderate. This could involve services such as welfare assistance and access to counselling. This is the type of response system of many counties in California (Reed and Karpilow, 2002; Berrick Duerr, 2018), the US state where the interviews for this book were conducted. Child protection workers in both countries make recommendations to the court (California) or the county board (Norway) to initiate a care order. This is a court order to move a child to an out-of-home placement (Berrick Duerr, Peckover, Pösö & Skivenes, 2015). It must be emphasized that the issues that child protection caseworkers in Norway and the United States face are similar – in both countries, workers deal with child neglect and abuse, and aim to keep children and young people safe.⁷

      In Norway, child protection investigations were started or under way for 46,903 children under the age of 18 years by the end of 2016 – 42.2 children out of 1,000 children in that age group.⁸ Also by the end of 2016, 12,636 children under 18 (11.4 children out of 1,000 children of that age) were in out-of-home care (Statistics Norway, 2017a). In the US in 2016, 3.5 million children (or 46.7 children per 1,000 children under the age of 18 years) were estimated to have received a child protection investigation or an alternative response. The number of children under 18 who were victims of child abuse and neglect was estimated to amount to 671,622 children nationally, or 9.1 per 1,000 children (US Department of Health and Human Services, Administration for Children and Families, Administration on Children, Youth and Families, Children’s Bureau, 2018a). In the US, 437,465 children between birth and 20 years were in foster care nationally by the end of September 2016 (US Department of Health and Human Services, Administration for Children and Families, Administration on Children, Youth and Families, 2017).⁹ This means that five out of 1,000 children in this age group were in foster care in the US.

      Table 1.2 illustrates the main differences between the welfare state and child protection systems of the two countries.

       Table 1.2:Legal, policy and organizational frameworks

	Norway	California
Welfare state context	●Social democratic^1	●Liberal/residual^1
Child protection system orientation	●Family service-oriented and child-centric^2 ●Low intervention threshold^4	●Child protection-oriented^3 ●High intervention threshold^4
Legal or policy guidance about children’s participation	●Yes: legislation^5 ●Yes: practice guidance^7	●Yes: caseworker practice guidance^5 ●Yes: court hearings^6
Child protection workers’ professional discretion	●Wide^8	●Narrow: investigations ●Structured Decision-Making (SDM)^9 ●Case reviews: Team-Decision-Making^10

      Sources:

      ¹ Esping-Andersen, 1990; Arts & Gelissen, 2002

      ² Berrick Duerr, 2011; Križ & Skivenes, 2014

      ³ Skivenes, 2011; Križ & Skivenes, 2014

      ⁴ Skivenes & Søvig, 2017

      ⁵ Berrick Duerr, Dickens, Pösö & Skivenes, 2015

      ⁶ Barnes et al, 2012; California Courts, 2019

      ⁷ BLD, 2009, cited in Eidhammer, 2014

      ⁸ Berrick Duerr, Dickens, Pösö & Skivenes, 2015; Križ & Skivenes, 2015

      ⁹ Berrick Duerr, Peckover, Pösö & Skivenes, 2015; Berrick Duerr, 2018

      ¹⁰ Berrick Duerr, Peckover, Pösö & Skivenes, 2015

      Norway and the US embrace different types of welfare state models (Esping-Andersen, 1990; Arts & Gelissen, 2002) and child welfare systems (Gilbert et al, 2011). In the US, a liberal or residual welfare regime, the state only provides residual services to the most destitute through means-tested social programmes. Norway is a social-democratic welfare state that provides universal public services to children and families (Esping-Andersen, 1990), such as subsidized daycare for children starting at the age of one year (Norwegian Directorate for Children, Youth and Family Affairs, 2017). The difference in the two countries’ social safety nets (wider in Norway than the US) and the extent of their public welfare provisions (more generous in Norway than the US) has implications for the variation in poverty levels and affects how the two countries score on the children’s well-being index for OECD (Organisation for Economic Co-operation and Development) countries (UNICEF, 2013). This index includes variables such as material well-being, health, safety and education (UNICF, 2013). The US is ranked comparatively low on this index, whereas Norway is ranked among the top five out of 29 countries. Norway is ranked number two in children’s ‘overall well-being’ (UNICEF, 2013, p 2), behind the Netherlands and ahead of Iceland, Finland and Sweden. The US is ranked as number 26, followed by Lithuania, Latvia and Romania (UNICEF, 2013).

      The orientations of the child protection systems of Norway and the US differ. The Norwegian child protection system is considered a ‘family service’ system, and the US system is ‘protection-oriented’ (Berrick Duerr, 2011; Gilbert et al, 2011; Skivenes, 2011).¹⁰ The differences between the two systems lie in the values underpinning them, and the way in which they approach children at risk. The main approach of family service systems is a preventative one; the child protection system seeks to provide universal public services to prevent more serious harm and prevent children’s out-of-home placements. The Norwegian Child Welfare Act (Articles 4–12) stipulates that services to families must be offered first, or there must be evidence that they will not be useful, before a child can be removed (Ministry of Children, Equality and Social Inclusion, 2017). Children tend to be older in Norway than in the US before they are removed, but the proportion of children living in care is higher in Norway than in the US (Skivenes, 2011; Gilbert et al, 2011).

      The US child protection system is oriented towards intervention once there is serious risk of harm to a child. The underlying normative principles of the US child protection system are the child’s safety, permanency (continuity of care and connectedness for the child), and child and family well-being (Goldman et al, 2003; Berrick Duerr, 2011). These normative legal foundations were mainly established by the Child Abuse Prevention and Treatment Act 1974 (CAPTA) (PL 93–247) and the Adoption and Safe Families Act 1997 (ASFA) (PL 105–89). Public child protection agencies in the US focus on investigating child abuse and neglect in a legalistic, adversarial and often standardized manner after the event, allowing for less professional discretion than in Norway (Berrick Duerr, 2011). Decisions are made expeditiously to protect a child from imminent risk of harm. Once child maltreatment is reported to the telephone hotline in California, for example, a child protection worker must assess the danger to the child speedily. If the child is in imminent danger, then a worker must investigate the case within two hours. If the situation is not an emergency, then the time frame for the investigation is up to 10 calendar days (Berrick Duerr, Peckover, Pösö & Skivenes, 2015). According to Berrick Duerr, Peckover, Pösö and Skivenes (2015, pp 371–2)

      [t]‌he investigation/assessment process can take up to 30 days. Once a decision is made to take temporary custody of a child, the child is removed by the child protection worker … followed by a presentation of evidence to court within 48 hours in order to sustain custody, and further evidence must be presented to court within 30 days to detain a child longer and/or to impose