In a recent case, Division Two stated that in applying the new guardianship statute the courts should look to termination cases for guidance. In re Guardianship of K.B.F., 175 Wash.App. 140, 146 n. 10, 304 P.3d 909 (2013). Yet, in this same footnote, the court noted that a preponderance of the evidence standard should be applied.

Considering H.M.'s multiple failures to attend service appointments, not just for the psychological evaluation but also for UA tests and drug treatment, as well as H.M.'s failure to regularly communicate with Tisino, the Department did not fail to offer the service by refusing to transport N.M. to the evaluation without H.M. having a confirmed appointment. H.M. relies on In re Welfare of C.S., 168 Wn.2d 51, 225 P.3d 953 (2010), and In re Guardianship of K.B.F., 175 Wn. App. 140, 304 P.3d 909 (2013), to support her argument that the Department inexcusably failed to offer necessary services, but her reliance on these cases is misplaced. In K.B.F., the Department stopped providing the parent with services after the child's permanent plan changed to guardianship.