Further, "a parent's compliance with counseling requirements is 'directly related to the establishment of a suitable home.'" Id. (citing In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009)). Indeed, "the problems and conditions for which the various . . . counseling efforts were conducted address matters[,] which make the home environment suitable for raising children. . . ."

Further, "a parent's compliance with counseling requirements is 'directly related to the establishment of a suitable home.'" Id. (citing In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009)). Indeed, "the problems and conditions for which the various . . . counseling efforts were conducted address matters[,] which make the home environment suitable for raising children . . . ."

" In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009); see also In re Shameel S., No. E2014-00294-COA-R3-PT, 2014 WL 4667571, at *5 (Tenn. Ct. App. Sept. 19, 2014) ("[P]arents desiring the return of their children must also make reasonable and appropriate efforts to rehabilitate themselves and to remedy the conditions that required [DCS] to remove their children from their custody." (citation omitted))

Further, "a parent's compliance with counseling requirements is 'directly related to the establishment of a suitable home.'" Id. (citing In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009)). Indeed, "the problems and conditions for which the various . . . counseling efforts were conducted address matters[, ] which make the home environment suitable for raising children. . . ."

Additionally, matters related to counseling and assessments are "directly related to the establishment and maintenance of a suitable home." In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009). This ground requires DCS to make reasonable efforts to assist the parent.

See, e.g., In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319 at *5 (Tenn. Ct. App. May 21, 2009) (concluding that "matters related to counseling and assessments" are "directly related" to the ground for termination of failure to establish a suitable home and stating: "While there is, of course, a physical element to the concept of a 'suitable home,' the problems and conditions for which the various assessment and counseling efforts were conducted address matters which make the home environment suitable for raising children and which keep them from becoming dependent and neglected."). As DCS notes, Mother does not address directly in her brief on appeal the trial court's finding that she abandoned the Children through failure to provide a suitable home.

The parent's failure to support is deemed willful only if the parent "is aware of his or her duty to support, has the capacity to provide the support, makes no attempt to provide support, and has no justifiable excuse for not providing the support." In re M.F.O, No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *3; 2009 Tenn. App. LEXIS 338, at *9 (Tenn. Ct. App. May 21, 2009) (citing Tenn. Dep't. of Children's Servs. v. Calabretta, 148 S.W.3d 919, 926 (Tenn. Ct. App. 2004)). We note that, in this case, there was no court order requiring Father to pay support, and the permanency plans did not require it. There is no evidence in the record that Father was told to whom any support should be paid. This does not, of course, relieve Father of the legal obligation to provide financial support for his children.

In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009).

Compliance with assessments and counseling is "directly related to the establishment and maintenance of a suitable home." In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *5 (Tenn. Ct. App. May 21, 2009).

However, "[t]he fact that a parent may not be under an order to pay support is not dispositive of the question of whether the failure is willful, as the obligation to pay support exists in the absence of a specific order." In re M.F.O., No. M2008-01322-COA-R3-PT, 2009 WL 1456319, at *3 (Tenn. Ct. App. May 21, 2009) (citing In re J.J.C., 148 S.W.3d 919, 926 (Tenn. Ct. App. 2004)). Here, the record reflects that Mother and Father failed to pay any support for the benefit of the Children, despite having set monthly income and the ability to spend money on Delta 8 and Delta 10 CBD products and on car repairs.