Inclusion of “follow all recommendations” language in mother’s case plan was harmless error. Mother challenged the “follow all recommendations” language in her reunification plan’s services section, arguing that the language fails to satisfy section 16501.1, subdivision (g)(2). The appellate court agreed. Section 16501.1, subdivision (g)(2) requires that case plans identify specific goals and the appropriateness of the planned services in meeting those goals. The case plan ordered for mother here included specific programs as well as “any other services that might be recommended in the future” by the clinicians providing those services. The case plan did not and could not identify how this latter category of unknown potential future services were “appropriate” for meeting the case plan’s goals. However, the court held that the error was harmless, as it would only cause concrete harm to mother if a clinician actually invokes this language and recommends a service for which the case plan has not identified a connection to plan goals. The court believed that is unlikely to occur in this case, and if it did, mother could raise the issue with the court in a section 388 petition.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/F079971.PDF