To prepare for the final hearing, the caseworker must:

  •   review the entire case file, both internal and external (including the removal affidavit, investigation report, DFPS history, criminal history, psychological evaluations, prior court reports, and all other documentation). When preparing for the caseworker’s specific testimony, the caseworker must contact the attorney representing DFPS;

  •   identify and collect any missing information (such as a disposition of criminal charges, the results of drug tests, a therapist’s recommendations, and probation reports);

  •   review and assess each parent’s compliance (or lack of compliance) with each requirement of the service plan (for example; “Of the 16 drug tests that the parent had scheduled, the parent had four unexcused missed tests, eight clean tests, two tests returned as positive for methamphetamines, and two tests excused for conflicts with court dates.”);

  •   prepare a chronology of the important dates in the case history;

  •   update case information about the child’s current status, including placement, medical, school, therapy, special needs, and all other significant issues;

  •   list facts and evidence that support the permanency goal. Whether the goal is termination of parental rights, permanent managing conservatorship, or another goal, always include the evidence that justifies that the goal is in the child’s best interest;

  •   identify possible witnesses and provide contact information;

  •   meet and confer with the attorney representing DFPS to discuss legal options, evidence, and strategies;

  •   follow up on pretrial preparations requested by the attorney representing DFPS;

  •   determine if regional practice requires the caseworker to take the following actions and then complete them, as appropriate:

  •   check if all parties have been served and verify the date of the return on the proof of service. If all parties have not been served, notify the attorney representing DFPS;

  •   confirm with the court’s clerk the hearing date and time, and notify all of the persons who are entitled to notice;

  •   arrive early for the final hearing to answer any last minute questions and help the attorney representing DFPS identify witnesses.