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This paper examines the discretionary reasoning of the judiciary in three jurisdictions, England, Germany and Norway, in cases deciding whether a newborn child is safe with her parents or intervention is necessary. Our analysis focuses on one specific dimension of decision makers' exercise of discretion, namely, if and how the strengths and weaknesses of the mother are considered. The data material consists of all decisions concerning care orders of newborns from one large city in Germany from 2015 to 2017 (n = 27) and 2016 in Norway (n = 76) and all publicly available newborn removal decisions in England for 2015–2017 (n = 14). The findings reveal a high number of risk factors in the cases and less focus on risk‐reducing factors. The situation of the newborn is considered to be harmful, as most cases result in a care order. Judicial discretion differs by how much information, and what types of factors, are included in the justification for the decision. A learning point for decision makers and policymakers would be to actively undertake a balancing act between risk‐increasing and risk‐reducing factors. [ABSTRACT FROM AUTHOR]

Child welfare removals of children are among the most invasive decisions a state can make toward its citizens, and typically it is the courts that make these decisions. These interventions are regularly exposed to criticism. In this paper, we examine if and how care order proceedings could be improved in England, Finland, Norway, and California, USA. We have asked the judiciary decision‐makers about their view on what should be improved. Our findings show that the organization of the proceedings, including time and staff, are identified as issues in all four systems. Furthermore, the preparations by the child welfare agency are also mentioned as an issue, for English, Finnish, and Californian decision‐makers. Very few decision‐makers indicate features related to the individual, situational, and contextual dimensions, which is interesting since this would be expected from organization theory. The strong call for change in the way proceedings are organized indicates a need for modernization as well as better use of available competency from child development experts. The respondents focus on the elements that a decision‐maker has direct experience with and knowledge about, and this is indeed worth noting for policymakers in the four systems. [ABSTRACT FROM AUTHOR]

Within Northern Europe, gendered roles and responsibilities within the family have been challenged through an emergence of different family forms, increasing cultural diversity, and progressive developments in welfare policies. To varying degrees, welfare policies in different countries support a dual‐earner model and encourage men to be more active as fathers by reinforcing statutory rights and responsibilities. In child welfare practice, there has traditionally been a strong emphasis on the mother as primary carer for the child; the father has been less visible. This paper explores, in four national welfare contexts, how child welfare social workers include fathers in practice decisions. Data were collected using focus group interviews with social workers from England, Ireland, Norway, and Sweden. Similarities and differences emerge in relation to services and the focus of social work assessments. However, overall, the research suggests that despite gains in policy and legislation that promote gender equality, fathers remain largely absent in child welfare practice decisions about the parenting of their children. From the research, we raise questions for social work practice and the development of welfare policies. [ABSTRACT FROM AUTHOR]

This paper compares how frontline staff in four national child welfare systems and policy contexts - Finland, Norway, England and the USA (specifically, California) - respond to questions about a scenario of possible harm to children. The countries have different child welfare systems that we anticipated would be reflected in the workers' responses ( n = 1027). The analysis shows differences and similarities between the systems, although often not in line with system expectations. There is also variation within the country samples. The study shows the complex interactions of individual and agency characteristics in addition to the role of proceduralised decision-making systems and professional discretion. Key Practitioner Messages Professional discretion differs., Proceduralised and high threshold systems result in less variation between workers' responses., System categories do not seem to capture the nuances of frontline decision-making. [ABSTRACT FROM AUTHOR]

This paper examines how child welfare workers in England, Norway and the USA (California) perceive children's participation building on 91 qualitative interviews. First, analysing the data using Hart's ladder of children's participation, we found that all Norwegian workers perceived children's participation as some form of decision‐making, whereas 40% of English and 35% of US workers embraced views of children's participation that can be considered token or non‐participation. Second, we coded the data for main themes and found that child welfare workers in all three countries perceived children's participation as hearing the child's opinion and information gathering. The themes of age, maturity and ability to form an opinion also emerged from the data. English workers' reflections about children's participation were more nuanced than their Norwegian and US counterparts; and US workers understood children's participation as children providing valuable information during the investigation of a case more frequently than workers in England and Norway. We discuss the implications of these findings on future research. [ABSTRACT FROM AUTHOR]

This paper examine how a sample of 301 child welfare workers in Norway, England and California, USA assess risk in cases of domestic violence. Decisions in child welfare cases are made under a high degree of uncertainty, and by using the vignette method, we explore whether child welfare systems and risk assessment approaches result in different assessment of risk level and substantiations. We find both cross‐country differences and similarities: Norwegian workers consider the risk level to be significantly higher than their peers in England and USA. However, workers' justifications for and identification of decisive factors in the case are strikingly similar across countries. These similarities are observed for both high‐risk and low‐risk assessors, and they may exist due to widespread knowledge about domestic violence and its negative consequences. We argue that the international differences in risk level assessments are due to system differences in the countries studied. [ABSTRACT FROM AUTHOR]

A recent study on the diving behaviour of European shags (Gulosus aristotelis (L.)) foraging in kelp forests off rocky coasts of Norway suggests surface durations are related only to the duration of the preceding dive, and hence are being used for respiratory recovery. These results contrast with earlier reports concerning shags foraging in highly tidal estuarine waters off the coast of Lundy Island, SW England, where there was a stronger relationship between dive durations and preceding pre‐dive surface durations, suggesting the use of preparatory variation in oxygen loading. These two datasets were collected using different methods, and statistically analysed in quite different ways, so the contrasting results here could be due to different methodologies rather than the ecological differences between the two foraging environments. Here, we re‐analyse the two datasets using similar statistical methods, and we confirm the contrasting results produced by the two datasets. We, therefore, conclude that shag breathing strategies do differ between these two marine environments, presumably reflecting adaptive facultatively plastic responses to differences in predictability of foraging dive durations. Off the Norwegian coast, unpredictable variation in the depth and availability of pelagic prey in complex environments may require more responsive post‐dive respiratory recovery on the surface after each dive. In the more uniform English near‐shore environment, however, pre‐dive preparatory oxygen loading customised to match predictable dive‐to‐dive variation in benthic prey depths and foraging durations, may be more time and energy efficient. [ABSTRACT FROM AUTHOR]

If children in child protection cannot be cared for by their natural parents, should they be adopted or live in foster home? Results from a study of representative samples of populations (n = 12 330), in eight European countries—Austria, England, Estonia, Finland, Germany, Ireland, Norway and Spain—and California, USA, reveal that people would recommend adoption over foster care, if a child in public care cannot grow up with their natural parent(s). There are cross‐country differences between populations, and examining if institutional context such as type of child protection system explains differences, we find that child maltreatment‐oriented systems are more supportive of adoption than other types of systems. Citizens having little confidence in the child protection system were only weakly correlated with preference for adoption. In conclusion, people prefer adoption as placement options for children in care are more than foster homes, and possible this finding reflects a sort of refamalialization of children into the private sphere. [ABSTRACT FROM AUTHOR]

Comparative penologists have described neoliberal and social democratic jurisdictions as though they exist at opposite ends of a continuum of inclusion and exclusion, and as though neoliberal states are inactive and social democratic states are invasive. This article, which is based on more than 129 interviews with men convicted of sex offenses in England & Wales and Norway, uses Cohen's work on inclusion and McNeill's typology of rehabilitative forms to complicate this simplistic binary. It argues that the punishment of men convicted of sex offenses in England & Wales was demanding but exclusionary; it imposed strict legal restrictions on these men during and after their imprisonment, blocking them from engaging in social and moral rehabilitation and providing a limited and treacherous route to change. In Norway, punishment operated in a way that was formally inclusionary but surprisingly laissez‐faire: Prisoners retained their legal rights during and after their incarceration, but the lack of opportunities to discuss their offending meant that their sentences were rarely experienced as meaningful, and their formal inclusion was not enough for them to feel substantially included after release. [ABSTRACT FROM AUTHOR]

Purpose: This study illustrates the huge untapped potential of quantifying the impact of culture in making meaningful comparisons across groups. Our focus is on cross‐national differences in nurses' reports of their relations with physicians, and how the measurement of this complex construct and the evaluation of true differences are related to dimensions of national culture. Design: We examine across 14 European countries the association between indices of national culture from the seminal work of Hofstede and 39,435 nurses' ratings of their relations with physicians. Multilevel confirmatory factor analysis was used to evaluate strong factorial invariance across countries and to examine the influence of power distance and masculinity. Findings: There was wide variation across countries in nurses' reports of their relations with physicians. Strong factorial invariance was shown for a one‐factor model, which confirmed that across countries the seven survey items measure a common factor of physician‐nurse relations. This model showed no country bias for any of the seven survey items, which suggests that differences across countries reflect true differences. These true differences were significantly associated with variation in country values of power distance, which showed a significant negative correlation with physician–nurse relations. Conclusions: Continuously pursuing a better understanding of characteristics that impact the studied indicators, such as national culture, is elementary to better understand the construct under study. In this application, country values of power distance negatively impacted nurse‐reported relations with physicians, which strongly varied across countries. Clinical Relevance: Better nurse‐reported relations between nurses and physicians link to higher nurse job satisfaction, lower emotional exhaustion, better nurse‐perceived quality of care, and lower patient mortality. The Practice Environment Scale of the Nursing Work Index is an excellent instrument to characterize variation in working relations between nurses and physicians as well as physicians' professional posture towards nurses. [ABSTRACT FROM AUTHOR]

Citizens' opinions on child protection public policy are a key dimension of the legitimacy of a political order. We have conducted a survey vignette on a representative sample of citizens ( N = 4,003) in England, Finland, Norway, and California, USA. The findings show that citizens' opinions are clearly in favour of adoption (75%) rather than long-term foster care (25%). Context may partly explain the findings, as the responses of the majority of Anglo-American respondents are in line with practice in their countries but for the Nordic respondents, there is a substantial discrepancy between citizens' opinions and on-going child protection practices. [ABSTRACT FROM AUTHOR]

Using the PISA 2015 releases in Norway and England, this article explores how PISA has been presented in the media and how the policy level has responded to the results. England will be used as an example for comparison. The article presents early media responses from the 20 most circulated daily newspapers in the two countries and discusses them in relation both to the national PISA reports in Norway and England, as well as the international report of the OECD. The media responses are further interpreted in light of previous research in both countries, with a particular focus upon Norway, where previous Ministers of Education have been interviewed about assessment policy and education reforms. [ABSTRACT FROM AUTHOR]

In a comparison of 53 child welfare workers' risk assessment based on a vignette case about a 9‐year‐old girl, less than one‐third of the child welfare workers in England and Norway, intended to work with fathers. Only 28% and 14%, respectively, suggested involving the stepfather, in spite that, the vignette said he lived with the girl and her mother. The invisible fathers in child welfare have been well documented, but fathers and stepfathers in particular, were surprisingly invisible in the Norwegian context, known for its strong focus on gender equality and institutionalized support for the father role. The child welfare workers seemed to prefer working with the mother and other professional agencies, rather than involving the father(s) and other family members. Although this may reflect the reality of families within child welfare, they are in contrast with the prevailing family ideology and practices in the society at large, both in England and in Norway. [ABSTRACT FROM AUTHOR]