Guidance on Looked After Children (Scotland) Regulations 2009 and the Adoption and Children (Scotland) Act 2007

PART XII REVIEW OF THE CHILD'S CASE, REGULATIONS 44 TO 47

This Part covers child care reviews, regulations 44 and 45; local authority responsibilities to visit children in placement, regulation 46; and termination of placements, regulation 47.

Regulations 44 and 45, Reviews

The purpose of looked after children reviews is to ensure that the identified needs of each child are being met in the short and longer term. It is important for local authorities to consider how they carry out these responsibilities in ways which contribute to children's sense of continuity. Local authorities should think about imaginative ways to carry out reviews, taking account of the range of different situations for looked after children. Children, carers and others need to know how concerns may be raised. However, there is a balance between appropriate monitoring which allows discussion about concerns and unnecessary over-intrusion, particularly when children are settled in long-term, stable and legally secure placements. Local authorities need to consider a range of ways to obtain children's views, without necessarily insisting that every child must attend review meetings. For example, there should be facilitation of looked after children's participation in their foster carers' reviews.

Reviews are a statutory requirement. They are the mechanism whereby the local authority ensure that they are fulfilling their obligations to care and plan for the child. Any decisions made by the review about the local authority services should be duly progressed. Some conclusions of discussion at reviews may need to be referred elsewhere. These can include a request for a Children's Hearing review if a change in the supervision requirement is indicated, or a referral to an additional scrutiny body within the local authority, in particular to the adoption or permanence panel.

Regulations 44 and 45 differentiate three groups of looked after children and there are slightly different provisions for about the frequency of their reviews.

1. Children who remain at home with birth parents under a supervision requirement; and also those for whom the local authority have a permanence order and the child's carers have some parental responsibilities and/or rights under that order. Their reviews are covered by regulation 44.

2. Children who are placed in a non-emergency situation with approved kinship carers or approved foster carers or in a residential establishment. This group includes children for whom the local authority has a permanence order but the carers do not have parental responsibilities and/or rights under that order. These children's reviews are covered by regulation 45(2), (4), (5) and (6). However, this group does not include children placed with a carer under regulation 39(1), for up to 12 weeks.

3. Children who are placed in short-term placements (often 'respite' arrangements) with kinship carers under regulation 14 and with foster carers under regulation 30; and also children placed with in an emergency with a carer by virtue of regulation 39(1), for up to 12 weeks only. These children's reviews are also covered by regulation 45, but the frequency of them is set out in regulation 45(3).

When the local authority has a permanence order for a child, they must be clear about whether of regulations 44 or 45 covers the reviews required. This will depend on the terms of the ancillary provisions in the permanence order.

Frequency of reviews under regulation 44

Regulation 44(5) and (6) allows for flexibility, as the local authority must agree the frequency of reviews with the child and the person caring for him or her, regulation 44(5). There is a fall-back provision when there is no agreement, regulation 44(6): the first review must "within 6 weeks of placement", and subsequent reviews within 12 months of the previous review. "Placement for these purposes should be treated as the date the supervision requirement or the permanence order was made. When the child is the subject of a permanence order and the local authority is discussing frequency of reviews, the birth parents do not have to be consulted about this, only the child and the carers.

In reality, regulation 44 covers two very different groups where the potential for flexibility may be helpful but will be exercised in different ways.

• Children at home on supervision requirements. Once the supervision requirement is made, there should be a meeting between the local authority, the parents and the child, depending on age and maturity, to lay down ground rules including frequency of reviews. More detail of the content of the work with these children and families is in the guidance for Children subject to home supervision. Early work is likely to be actively addressing the assessment and care planning requirements in regulations 3 to 5. This may lead on to considering contracts with the birth parents and, if appropriate, children and young people, about areas to address, changes required and services to be provided. Good intervention will also require a careful monitoring and review of progress to reinforce improvements, to maintain momentum and to look at agreed aims and targets. This will require active reviewing, beyond the minimum fall-back frequency indicated in regulation 44(6). Where the use of a supervision order is proving effective, there should be a clear picture of this to bring to the annual Children's Hearing review, together with an assessment of the need for continuing compulsory supervision. Where there are areas of contention, looked after reviews will need to consider these, and where necessary request to an early Children's Hearing review. Where the situation has been stabilised, there should be a looked after review prior to the annual Children's Hearing review, to clarify the local authority view on continuation of the order. If it is agreed that the supervision is working effectively and should continue, this is the point where there may be consideration of reduction in the frequency of looked after reviews. Similar considerations apply when a child who has been placed returns home under a supervision requirement. This is often a vulnerable situation, where allowing a child to remain at home, or returning them to the care of birth parents, includes a balancing of benefits and risks.
• Children subject to a permanence order when carers have some parental responsibilities. Where the child is already with permanent, kinship or foster carers who have some parental responsibilities for the child under the permanence order, the aim is to underpin the stability of the placement by a less intrusive reviewing process. This should be balanced with the need to ensure that the carers are receiving all the necessary support in caring for the child, and that the child's need for direct services is recognised. It should not, therefore, be assumed that a more limited number of reviews is required. However, arrangements for reviews should allow as much flexibility as possible, particularly about whether the child attends, how his or her views are obtained and the venue. Where the child is living with kinship or foster carers who have some parental responsibilities but a permanent placement for the child is still being sought, it is very important to ensure that focus continues on completing the permanence plan. It would therefore be best practice to try to agree with the child and carers to have reviews as frequently as for other looked after children under regulation 45(3), that is, every six months.

Frequency of reviews under regulation 45

There are two different frequency provisions in this regulation, as between paragraphs (2) and (4) and paragraphs (3) and (4).

Regulation 45(2) and (4) sets out the pattern of reviews for children placed in non-emergency situations with kinship carers, with foster carers and in residential establishments. Regulation 45(3) and (4) sets out the pattern of reviews for children placed by virtue of regulation 39(1) in emergency situations, with kinship carers, with foster carers and with non-approved carers. Local authorities should ensure that their procedures for reviews under this regulation are tied in with those in regulations 38, 39 and 41, for reviews of emergency placements, to make certain that they achieve the correct inter-relationship between the various regulations. Please see guidance on Reviews of emergency placements.

The provisions in regulation 45(3) and (4) also apply to children placed in short-term placements (often 'respite' arrangements) with kinship carers under regulation 14 and with foster carers under regulation 30.

Children reviewed at the frequencies in regulation 45(2) or (3) will be:

• accommodated under section 25 of the 1995 Act, on a 'voluntary' basis, including most children on short-term placements; or
• subject to supervision requirements from the Children's Hearing, under section 70 of the 1995 Act; or
• subject to orders, warrants, or authorisations from the sheriff or the Children's Hearing system, under the 1995 Act; or
• subject to permanence orders under section 80 of the 2007 Act, when the carers have no responsibilities or rights under the orders.

Children who have been placed under court orders, hearing warrants, etc will usually have been reviewed under the emergency review provisions, regulations 38, 39 and 41. However, those provisions do not run beyond the six week review for emergency placements with carers, or the three day review for emergency placements in residential establishments. Many Children's Hearing cases involve warrants for a considerable time until grounds for referral are established or not established. Therefore, the review system under regulation 45 could easily start to apply to children in that situation. Within six weeks of an emergency placement in a residential establishment, a review will be required under regulation 45(2)(a). The reference to regulation 39(1) in regulation 45(3) recognises that the review within six weeks is already provided for when children are placed with carers in an emergency. However, within three months of that six week review, a further review will be required under regulation 45(3)(a).

Regulation 45(2) provides for the first review within 6 weeks of a planned placement. The next review should take place within 3 months of that 6 week review, i.e. within 4_ months of the placement. Thereafter, there should be further within 6 months of each previous review. A number of local authorities may hold reviews at shorter intervals in the early stages of looking after children, especially where they are planning for young children with an intensive intervention or support programme, to establish if return home is feasible, and if so, followed by active planning for stability and permanence for the children. The wording in regulation 45(2) (and in paragraph (3) as well) is about the periods within which reviews must be held, not the precise time at which they must occur.

Regulation 45(3) provides for reviews of:

• children in a series of planned short-term placements with kinship carers (regulation 14);
• children in a series of planned short-term placements with foster carers (regulation 30); and
• children placed with carers on an emergency basis.

The first review should take place within three months

• of the placement, in short-term arrangements; or
• of the six week review under regulation 39(3).

In other words, the first review will be within 4_ months of the placement. Thereafter, there should be further reviews within 6 months of each previous review. As with reviews under paragraph (2) local authorities may hold reviews at shorter intervals, particularly for placements which were made on an emergency basis.

So far as children in short-term placements or on short-term breaks are concerned, the matters for discussion at reviews may often be different from those when children are placed away from home. There are now a wide range of short breaks schemes. Some may cater for children who are already looked after, either on home supervision requirements or as a support to foster carers looking after very challenging children. Others have been established as services for families who are caring for children with significant disabilities or ongoing medical conditions. A number of these arrangements may last many years. The ethos and purpose of reviews at regular intervals in these situations needs sensitive consideration.

Further review requirements are imposed for every child covered by regulation 45, whether their reviews are under paragraph (2) or (3). These are in paragraph (4), which requires local authorities to arrange reviews:

(a) before they make a decision to seek a Children's Hearing review for a child whose supervision requirement they think should be varied or terminated;

(b) before they apply for a permanence order; and

(c) under any other circumstances, when a Children's Hearing is arranged for the child.

It is clearly important, when the local authority are providing a report to a Children's Hearing, that they have had an opportunity to discuss their up-to-date position in preparation. In some cases, the date of a looked after review may be decided in relation to anticipated steps involving Children's Hearings; in other cases, a parent may request a Children's Hearing review following a contentious looked after review where the local authority position is clear.

Focus of reviews

Regulations 44 and 45 lay out very similar requirements about what reviews should be considering and looking at, who to consult and what to assess. Every review should provide the opportunity to:

• take stock of the child's needs and circumstances at regular, prescribed time intervals, and ensure the local authority are fulfilling their responsibilities for the child's development and well being;
• consult formally with parents and children, acknowledging and taking into account their views;
• assess the effectiveness of current plans as a means of securing the best interests of the child;
• oversee and make accountable the work of professional staff involved; and
• formulate future plans for the child.

While reviews generally need to address the two main strands in the Child's Plan - the planning process and the child's personal progress and development in response to the local authority service - the emphasis will vary depending on the type of situation being reviewed and the stage in the case. The local authority should have in place mechanisms for ensuring that reviews are carried out efficiently and effectively for the range of situations of all looked after children. This requires a framework for all types of reviews covered in regulations, and an overview of how they fulfil their purpose in individual situations.

A framework for reviews

The regulations are clear about frequency of reviews, who to consult and the broad areas to address. They are not prescriptive about how they should be carried out. This should be laid out in local authority procedures. A significant number of local authorities have independent reviewing officers who ensure a well run reviewing process and have contributed significantly to the development of this important area of work. The differing sizes, structures and geographical aspects of local authorities in Scotland mean that some variation in the exact provision for carrying out reviews is possible, as long as authorities can demonstrate that they meet the requirements and fulfil their functions. There may also be some variation within individual authorities if these contribute to the effectiveness of reviews. This would provide scope for reviews that are tailored to meet the needs of certain services such as short breaks for families that include a child with severe disabilities, or newly developed kinship care projects. It may be that slightly different provision is more likely to be responsive to work with children looked after at home under a supervision requirement as opposed to those in a local authority placement. Different provision will be necessary for children looked after on permanence orders with long-term carers, particularly when those carers have some parental responsibilities and rights

What should be common to all reviews is:-

• chairing of the review by someone who has no direct day-to-day responsibility for the case, to maintain the objectivity and accountability for the management of the case;
• a clear written record of the outcome of the review and any decisions made, in line with regulations 44(4) or 45(6);
• explicit information about the decisions that may be made at the review; those which may be discussed but where the Children's Hearing make the decision; and those where the decision at the review needs to be referred to the adoption/permanence panel for additional scrutiny before becoming an agency decision about permanence;
• guidelines, based on the expertise of those conducting reviews, about handling aspects such as how children, birth parents and carers are involved and supported in contributing to the review, and how conflicting views will be managed; and
• procedures governing the range and format of information brought to different types of review.

Local authorities need to ensure oversight, at intervals, of the operation of their reviewing processes, considering both the ways they maintain the momentum in implementing plans for children; and also lessons for the local authority in improving services.

Some special considerations

Reviews of children in kinship care

From the children's point of view, the circumstances which led to them no longer living with their birth parents may be comparable to that of other children who are placed by the local authority with foster carers or in residential establishments, and this is reflected in the reviewing requirements in relation to each child's plan. The approach to kinship care covered in the guidance to PART V KINSHIP CARE is based on the intertwining of children's needs and the ability of the identified member of their kinship network to respond to those needs. This covers the process of approval of kinship carers. There is no separate review process in the regulations for kinship carers in the way there is for foster carers. The ongoing appropriateness of the placement will be part of the child's review. Kinship carers themselves, however, may have their own concerns or needs that do not sit comfortably as part of children's review. These may include training and support issues for them as carers; and personal events and changes in their circumstances that are not appropriate to discuss within a group established to focus on the child's needs. There should be space annually, therefore, for kinship carers to reflect on their own needs in relation to caring for children, and this element may be planned and linked to the children's reviews.

Reviews in planning for permanence

Looked after reviews are clearly the key forum for developing the plan for a child, for monitoring progress and for identifying where change is required. This may be to remain at home without the need for a supervision requirement, or to return home, or not to return home if progress has not been achieved. It should be clear from the start of each child's involvement in the looked after system that the aim of local authority involvement is to achieve stability and security for the child, in an environment where they are safe and their developmental needs met. Parents should be clear about the efforts they are expected to make to achieve this, how they will be supported in this and also to recognise that if this cannot be managed, alternative plans will be made.

It would normally be expected that within a timescale of six months there should be a clear picture of the direction in an individual case. Where a child is placed by the local authority and he or she has not returned home by this stage or if significant progress towards that has not been achieved, then the review should consider whether a plan for permanence away from birth parents is required. Where the review at this stage decides:

(a) the plan should no longer be the return of the child to the birth parents; and

(b) the child would benefit from growing up in an alternative family or in another long-term, stable placement; and

(c) this requires a legal change to underpin the security of a placement,

the programme of work required should be set out, including referral to the adoption/permanence panel for it to consider a recommendation to make this a full agency decision.

These are some of the elements in this work.

• Explaining to the child in an age-appropriate way, that returning home is no longer planned; and providing opportunities for the child to express his or her views, or if too young to do this verbally, observing and also asking the carers to look out for any reactions. Consideration should be given to offering the child access to a child advocacy service or other provision to support him to her in expressing views.
• Clarifying the change in the child's plan with the birth parents, and explaining the reasons for this, the different stages in going along this path and how they can make their views known at each stage. As well as advising them on seeking their own legal advice, consideration should be given to the allocation of a separate worker to work with the parents through the process or to seeking other options for counselling and support, depending on local availability.
• Where a child is already with kinship carers, discussing their position now that long-term care is needed.
• Where the child is placed with foster carers, exploring whether there are other members of the child's kinship network who could offer permanent care.
• Establishing with the child's current carers whether they wish to continue looking after the child on a permanent basis.
• Meeting the local authority's legal adviser to explore the options available and the evidence for these.
• Gathering together all the information required for the referral to the adoption/permanence panel and writing the report for this.
• Completing the next stage of presenting the case at the adoption/permanence panel and receiving the agency decision.
• Where the child is subject to a supervision requirement from the Children's Hearing, considering whether a Children's Hearing review should be held at this stage, prior to any advice Hearing after the agency decision.

In making the decision to go down this route and setting out the next steps, the looked after review should also state the timescale within this is to be achieved. The maximum time to complete all these steps should be by the next six month review, but may be sooner for a young child and where much of the information is already clear. A small but significant group for whom this is particularly important is young infants when there have been pre-birth child protection conferences, because of the strength of information about older children of these parents and the consequent risks to any other children. Where there has been a child protection order from birth followed by a supervision requirement and no evidence of change that would enable any consideration of a return to birth parents, the early reviews should already be actively addressing the need for a permanent alternative.

Local authorities should also consider permanent plans when they are reviewing children whose parents are dead or have disappeared, and whom they are looking after under section 25 of the 1995 Act. This will be comparatively straightforward when the child is an abandoned baby, all efforts to trace the parents have failed, and the alternative is adoption. However, a local authority should also consider permanent plans for an older child in this position. If no other family members are able to be traced, or are unwilling to care for the child, long-term care under section 25 is not a satisfactory option. There will be no-one who may exercise parental responsibilities and rights for the child and no-one to question the care arrangements. The local authority should consider applying for a permanence order, or planning for adoption, depending on the age of the child and other factors.

Regulation 46, Local Authority visits

Regulation 46 provides for local authority visits to children in placement with foster carers, kinship carers and residential establishments. It also specifically includes placements by virtue of regulation 39(1), which are emergency placements under regulation 36 which have continued after the three working day review. These placements may be with people who are known to the children but are not approved kinship carers, as well as with approved kinship or foster carers.

Regulation 46(2) sets a minimum of a visit within the first week of placement and thereafter at least every three months. Regulation 46(3) specifies certain situations when the local authority must carry out visits. Regulation 46(4) requires written reports for all visits undertaken.

Visits may fulfil a number of functions which are important for the child and may cover some of the following matters.

1) Oversight of the safety and wellbeing of the child.

The first visit at the beginning of a placement should set the foundation for this, in recognising any potential risks or stress areas in the placement and also beginning to identify how the carers will meet the particular care needs of the child and promote development. Foster homes and residential establishments are complex environments which may already be managing very differing needs within themselves, and a new distressed or traumatised child will inevitably have an impact. Planned moves may have already identified any potential stress areas but these have to be checked in reality. A significant percentage of kinship placements are made in an emergency before an assessment can be completed. Although the child may be familiar with the environment, where the child is looked after, the local authority has a responsibility to ensure it is safe and appropriate for the child, and that any risks from the child remaining within the kinship network are fully addressed.

Regulation 46(3)(a) emphasises this with the duty to ensure that visits are made when it is "necessary or appropriate to safeguard or promote the welfare of the child". This should go beyond a reactive response and the minimum visiting requirements to a more pro-active approach of explicitly recognising both the opportunities and risks in any placement, and also establishing clear lines of communication. For children placed for the first time, this will include explaining to them the role of their social worker and age-appropriate ways of keeping on touch with their wishes and needs.

2) Children placed in foster or residential care

Where children are being accommodated in foster or residential care, this will be a huge disruption in their lives. Anxiety and stress are normal for anyone entering a new environment, and this will be particularly so for vulnerable children who may be placed in distressing circumstances with little preparation. The children's carers will, of course, play a vital role in helping them through this period of transition. The particular value of social workers at this point is frequently the link back to the children's birth families and connections with their familiar environment. The intensity of this may alter over time as the children become accustomed to the new environment, but questions about what is happening to family members and contact issues will remain. For more planned moves, and where children are moving between different care placements, this may seem less intense; but during any move to somewhere new, there is a particular role for known social workers who can be a bridge between children's old and new environments.

It is especially important to consider these issues when children are being placed at a distance. Regulation 46(2) refers to visits on behalf of a local authority. Local authorities may consider that at least some of the task may be carried out be an appropriate person from another agency in the area, as long as it is clear that the placing authority remains responsible for the children, that this is a service for the children and that the written reports required under regulation 46(4) are supplied. At the same time, it is these children who are at most risk of feeling cut off from their family, home area and community.

While this type of issue may be easier for children going to kinship carers, there will still be adjustments to be made to family relationships; and very strong views may often be held and expressed within that network. These may surface during the moves into placements and cause extra tensions.

3) Children's views

At all points of the assessment and planning for the child, the child's wishes and feelings must be addressed. The social worker is responsible for the reports required and these views must be included. A significant part of these should be based on the worker's own direct observations and communication with the child. This will not be wholly dependent on the visits to the placement. For a young child, the day to day observations by carers of the child's behaviour and reactions may be more revealing; and an older child may share as much through email and telephone contact as face to face. Visits must, however, play a part in the child's perception of participating in the decision making process.

4) Visits to support carers

Regulation 46(3)(b) makes provision for visits to support the child's carer in safeguarding and promoting the child's welfare. Foster carers and staff in residential establishments should have strong support mechanisms in place, recognising carers' needs. Inevitably, these work best in partnership with the child's social worker who is responsible for the service to the child. Some support may be about accessing further services for the child and visits are only one part of the means of communication with carers. For many children and young people, however, this works best if they see their social worker and carers sit down together, and with them as well, to sort out issues such as contact arrangements, setting the ground rules for managing certain behaviours or making future plans.

5) Visits requested by children or carers

Regulation 46(3)(c) makes provision for the child or carer to reasonably request further visits. Sometimes this may be part of a plan or programme at a particular point, at other times it may be an expression of a feeling of lack of support. Wherever possible, any request should be addressed through the existing channels such as a line manager or team leader or the review process, to find a feasible arrangement that can be sustained and is acceptable to the carer and/or child. Where there are real problems in resourcing this at an operational level, senior management should be alerted.

Overall, in considering the purposes of local authority visits, there are times when they will be particularly important. These times include: the start of a placement; times of transition; times when there are significant events or potentially traumatic circumstances for the child; periods when the child may need a particular intervention such as life story work; and when there are plans for changes such as moving into independence. All of these are likely to require more than the minimum visits. At other times, the need for visits may be seen more as maintaining a relationship with the child and keeping in touch with their development, where a 'lighter touch' may be more appropriate and acceptable to a child who is settled in a placement. Local authority procedures should acknowledge this, especially in relation to areas such as unannounced visits or expectations of seeing a child on his or her own, so that the child receives a service that both ensures safety and wellbeing while he or she is looked after and also is sensitive to the child's own views of that experience.

Where arrangements are being made to supplement face to face visits with computer or mobile telephone links with a child, care needs to be taken to discuss the details of this with the child's carers. Each local authority should have up-to-date guidelines on the appropriate use of such communications, both their positive potential and also the steps that may be needed to safeguard each child as much as possible. These types of links should be addressed at the outset of a placement and reviewed as necessary, taking account of both differences in policies etc when a child is being placed outwith the local authority, and also the individual circumstances of each child.

Regulation 49 also has provisions about local authority duties to visit children. These are specific duties when a looked after child is placed with carers from a registered fostering provider. They include duties for an officer of the local authority to visit, so cannot be delegated to staff of another agency. Please see guidance on Regulation 49.

Regulation 47, Termination of placement

Regulation 47 enables a local authority to terminate a placement if it appearsto be no longer in the child's best interests. This possibility should have been discussed in relation to signing the kinship carer agreement in Schedule 5 or the foster carer agreement in Schedule 6. The primary responsibility of the local authority is obviously to act in the best interests of the child. An abrupt termination of a placement will cause great concern and be distressing for a child, so termination requires a careful decision-making process, even when there is only a short period of time, with clear management accountability and a clear record made of the reasons for such a termination.

Part X (please see guidance on EMERGENCY MEASURES) of the regulations, on emergency measures, refers at intervals to the importance of asking, following an emergency placement, about whether the placement continues to be in the best interests of a child. A placement may need to be made at short notice when there is limited choice available. At the time, it may also be recognised that this is not the most appropriate placement in the longer term, either because of a mismatch in the known skills and interests of the carers, or because the child had to be placed separately from siblings or with a family not equipped to meet needs arising from the child's ethnicity, religion or culture. It is important to address such issues actively, to avoid conflict at a later date when carers and child have become attached but the plan is to move the child.

Similar issues may arise when a young child is placed in an emergency with a registered fostering service, the carer becomes attached, the plan for the child becomes placement in a permanent family and the local authority wishes to move the child to a different placement. The best interests of the child, especially if adoption is the preferred route, the wishes of the carers and the considerations in using resource from a registered fostering service may create numerous debates and tensions. Some of these are interagency issues, which need open discussion, but in a child-centred service the crucial question, as in other decisions to terminate a placement, is: 'will it make sense to the child in the future, when he or she comes back to question decisions made for him or her?'

A key reason for this provision is the recognition that, in a small number of cases, the care provided for a placed child is not safe or is inadequate. If there is a real risk to a child, there is no question about the need to act and this would be handled under child protection procedures. More complex questions arise in situations where there are allegations which must be explored but no objective evidence of harm to a child. The risks arising from an allegation must be balanced against the potential damage to a child of a precipitate move, especially if the child resists this. The whole area of investigating allegations goes beyond what can be covered in this guidance. Please see the Best Practice Guidance: Responding to Allegations Against Foster Carers]

In any situation where termination of a placement is being considered, there should be a clear record of the reasons for this step, the risk assessments made and the plans to address the impact on the child. Consideration should be given at the outset to who is best placed to carry out the direct work with the child in ascertaining his or her views and explaining what is happening, whether the termination is a result of an allegation or other developments. Equally, where a foster or kinship carer has asked for a child to be removed, the same attention needs to be given to minimising the shock of a quick move for the child and introducing as much of an element of planning as may be feasible.

Where a child is subject to a supervision requirement, a planned termination of placement will require a Children Hearing review to vary or terminate the requirement, and allow the move. If the child is placed away from home and has to be moved urgently, the local authority may arrange this under section 72 of the 1995 Act. Such a move must be advised to the Principal Reporter immediately for a Children's Hearing review to take place within seven days of the move.