What Do Custody Evaluators Agree About? The Bernet, Baker & Adkins (2022) Definitional-Consensus Survey

Love Over Exile is a plain-language research and policy archive on parental alienation, written by Malcolm Smith — an alienated parent and author of the forthcoming book Love Over Exile — for non-specialist readers (other alienated parents, family members, therapists, lawyers) who want to understand the evidence base without a psychology qualification or a journal subscription. This page is one entry in that archive.

What the Researchers Asked

When a child custody evaluator in the United States is asked to assess a contested family case, they reach for a working vocabulary. They classify the child’s behaviour. They differentiate alienation from estrangement. They name the favoured parent’s tactics, and they decide whether the framework in front of them — most often Bernet’s Five-Factor Model — is the right tool for the case.

The vocabulary is clinical, but it is not only clinical. Courts read evaluator reports. Judges adjudicate between competing experts. Other evaluators are reviewed against the same vocabulary in case-management proceedings.

The question Bernet, Baker and Adkins set out to answer in 2022 is whether that working vocabulary is actually shared. Do US custody evaluators — the senior, experienced subset of forensic-mental-health professionals who run these assessments — agree on what parental alienation is, what parental estrangement is, what counts as a contact refusal, and what the Five-Factor Model captures?

The framing the authors give in the abstract is that the public appearance of “controversy and discord” in the field misrepresents the actual state of practitioner opinion. They want to test whether disagreement is real or surface-deep.

How the Survey Was Designed — Methodology in Plain English

The paper is a cross-sectional online survey, not a Delphi study. That distinction matters and should be carried through every reading of the result.

A Delphi study would have run multiple rounds. Round one would have collected agreement; round two would have fed those results back to the same panel; round three would have measured how the panel converged or diverged after seeing each other’s responses. Consensus would have been earned through iteration.

This paper is one round. Respondents saw 11 pre-formulated definitions written by the authors, and rated agreement once on a 5-point Likert scale from “strongly agree” to “strongly disagree”. There was no feedback loop and no convergence process.

The recruitment frame was a single professional custody-evaluator listing — almost certainly a US-based directory, though the abstract does not name it specifically. Email invitations went to listed evaluators with a link to the online survey. Of approximately 135 invitees, 119 responded — an 88 percent response rate.

That 88 percent response rate is unusually high for a professional online survey. Typical professional surveys report 15 to 30 percent. The high rate suggests strong engagement with the topic among the target frame — and it is the paper’s clearest methodological strength.

The total n is 119 evaluators. The frame is a single listing. The instrument is a custom-built questionnaire created specifically for this study, not a previously validated instrument. The items were generated by the authors through “expert input and preliminary field-testing” — that is, the authors and consulted experts wrote the definitions, then field-tested wording before fielding the survey.

Reading the methodology in plain English: the authors asked one specific subset of working US practitioners — custody evaluators on a particular listing, who had self-selected onto a directory of practising evaluators — to endorse pre-written definitions in one round. They got an unusually high response rate. The 80 percent endorsement figure is conditional on those design choices.

The 11 Definitions and the 80 Percent Headline

The single most-cited sentence from this paper is the abstract’s verbatim conclusion:

“Results revealed that roughly 80% of respondents agreed or strongly agreed with each of the 11 definitions, which indicate a high degree of consensus regarding this phenomenon.”

What that means precisely. For each of the 11 definitions surveyed, approximately 80 percent of the 119 respondents picked either “strongly agree” or “agree” on the 5-point Likert scale. The remaining 20 percent includes “neither agree nor disagree”, “disagree”, and “strongly disagree”.

The journal-listed keywords are “DSM-5; Five-Factor Model; contact refusal; estrangement; parental alienation” — the spine of the survey. The abstract does not list each of the 11 items verbatim, and the article body is paywalled at Wiley Online Library; the per-item agreement percentages are in Tables 2 or 3 of the body.

What we can reconstruct from the keywords and from the broader Bernet-camp literature is that the 11 items almost certainly include parental alienation, parental estrangement, contact refusal, alienating behaviours, the Five-Factor Model and its component criteria, alignment, hybrid cases, and the relationship of parental alienation to existing DSM-5 and ICD-11 codes.

What this paper measures, and what it does not

What the result establishes: that working US custody evaluators on this professional listing share working definitions of parental-alienation terminology. They mean roughly the same things by the same words.

What the result does not establish:

• Prevalence. The paper does not measure how often parental alienation occurs in the population. For prevalence, cite Harman, Leder-Elder and Biringen (2019) for the United States or Hine, Harman, Leder-Elder and Bates (2025) for the United Kingdom.
• Validity. The paper does not test whether the constructs (parental alienation, the Five-Factor Model, alienating behaviours) predict outcomes, are reliably measurable, or distinguish alienated from non-alienated children. Definitional agreement on what a term means is not the same as evidence that the underlying construct is real.
• DSM-5 or ICD-11 inclusion. The Bernet camp’s argument that parental alienation is captured by existing codes (Caregiver-Child Relationship Problem QE52.0 in ICD-11, and CAPRD, Parent-Child Relational Problem and Child Psychological Abuse in DSM-5) is a coding argument, not a recognition argument. The World Health Organization’s official 2020 position is that parental alienation “is an issue relevant to specific judicial contexts”, not a health-care term, and the index entries “parental alienation” and “parental estrangement” were deliberately removed from ICD-11.
• Field-wide endorsement. The frame is custody evaluators on a single listing — not judges, not domestic-abuse specialists, not child-protection workers, not the broader forensic-mental-health workforce. The 80 percent figure is conditional on being a custody evaluator on this listing.

The decision tree the survey maps onto — Five-Factor Model + the surrounding constructs

The 11 definitions sit inside a clinical decision tree the Bernet-camp literature uses to differentiate alienation from estrangement and from normal contact difficulties. Reading the tree makes the survey’s structure visible.

Read Alongside Kline Pruett (2023) — Two Surveys, Two Frames

The most important piece of context for this paper is the contrasting interdisciplinary survey published the year after — Kline Pruett, Johnston, Saini and colleagues (2023) in Family Court Review.

Where Bernet, Baker and Adkins surveyed 119 US custody evaluators on a single professional listing, Kline Pruett and colleagues surveyed 1,049 interdisciplinary family-justice professionals. The 2023 sample includes judges, lawyers, mental-health professionals and evaluators, recruited across a much broader frame.

The 2023 finding is that practitioners disagree substantially on whether parental alienation is “a valid and widespread phenomenon versus a legal strategy to counter intimate-partner violence and child-abuse allegations”. The authors also note that evaluators are confident in their parental-alienation judgments “despite little formal instruction on the underlying issues”.

The two surveys are not in technical contradiction. They survey different populations (custody evaluators vs. all interdisciplinary professionals); they ask different items (pre-formulated definitions vs. attitudinal questions); they have different sample sizes (119 vs. 1,049). But the contrast is striking and the article must report it.

The honest framing for any reader of the consensus paper is this: definitional agreement among 119 US custody evaluators on a specific listing is not the same as field-wide consensus across the broader family-justice system. The 80 percent figure is conditional on the frame the paper chose — and a larger 2023 survey, with a wider frame, found markedly less agreement.

Comparison table — three surveys on parental-alienation expert opinion

	Bernet, Baker & Adkins (2022)	Kline Pruett, Johnston, Saini et al. (2023)	Garber, Simon, Bernet & Griffin (2024)
Where published	Journal of Forensic Sciences, 67(1)	Family Court Review, 61(4)	Family Transitions, 65(1)
Type	Cross-sectional online survey	Cross-sectional online survey	Consensus-building meeting; published synthesis
Sample	n=119 US custody evaluators on one listing	n=1,049 interdisciplinary family-justice professionals	Senior researchers (Bernet camp + Garber-Simon critics)
Method	Single-round endorsement of 11 pre-written definitions	Multi-section attitudinal items on belief and practice	Convened meeting to negotiate shared positions
Headline finding	~80% agreed with each of 11 definitions	Substantial disagreement on validity vs. legal strategy	FFM “is a good foundation but needs to be more fully developed and defined”
Frame strength	High response rate (88%); defined population	Larger, more diverse, broader frame	Direct engagement between framework authors and critics
Frame limitation	Single-source listing; self-selected; one round	Self-selected respondents; differing professional roles	Senior figures only; not representative of practising field
What it establishes	Terminological agreement among one subset of US evaluators	Substantial field-wide disagreement on PA validity	Partial walk-back of strongest FFM claims by senior figures
What it does not establish	Prevalence, validity, or field-wide endorsement	Final answer on PA validity — surveys disagreement, not truth	New empirical evidence — synthesises existing positions

Two readings of the table. First, the Bernet, Baker and Adkins (2022) figure is real but narrow — it captures one specific population’s working vocabulary, and its limitations are the limitations of any single-source survey. Second, the picture across all three publications is not “consensus” in the field-wide sense but layered evidence: shared terminology among working US evaluators, substantial disagreement across the broader interdisciplinary field, and a senior-figures consensus-building meeting that walked back the strongest version of the strongest claim.

The article should quote the 80 percent figure and quote the Kline Pruett finding immediately afterwards. Either alone, without the other, is misleading.

What This Means for UK Practice

The Bernet, Baker and Adkins (2022) paper is a US definitional-consensus paper. The frame is US child custody evaluators; the constructs are the US Bernet-camp vocabulary; the diagnostic placement discussion is anchored in DSM-5 and ICD-11. UK readers — particularly UK alienated parents navigating Cafcass and the family courts in England and Wales — need to read the paper through the right adapter.

The UK adapter is the Family Justice Council December 2024 guidance on responding to allegations of alienating behaviour. The FJC explicitly rejects the “parental alienation syndrome” framing as having “no evidential basis”, and adopts alienating behaviour as the operative term-of-art with a defined three-element test (RRR, AJR, AAA, AB, PB).

UK family-court practice does not import the US “custody evaluator” role. There is no equivalent UK directory of practising custody evaluators; the parallel UK roles are the Family Court Adviser within Cafcass (or Cafcass Cymru in Wales), and regulated clinical or counselling psychologists registered with the Health and Care Professions Council (HCPC) or chartered with the British Psychological Society (BPS). Following Re C and Re GB in 2023 and the FJC December 2024 guidance, unregulated psychologists are effectively excluded from giving expert evidence on alienation in England and Wales.

The relevant UK question is therefore not “do US custody evaluators agree on parental-alienation terminology?” but “how does UK practice interact with that US terminology?” Three answers:

• The terminology partially translates. The FJC’s “alienating behaviour” is closer to Factor 4 of the Five-Factor Model (multiple alienating behaviours by the favoured parent) than to the full diagnostic concept of parental alienation. The FJC’s “RRR” maps onto Factor 1 (contact refusal). The FJC’s “AJR” is the differential rule-out for estrangement; the FJC’s “AAA” is the differential rule-out for affinity-alignment. The vocabularies overlap but are not identical, and the UK-side decision is a legal finding by the court, not a clinical diagnosis by an evaluator.

• The empirical floor is now in place. The Hine, Harman, Leder-Elder and Bates (2025) UK prevalence study, in the Journal of Family Violence, established that 39 percent of separated UK parents experience alienating behaviours when asked directly and 59 percent on a 30-item behavioural inventory. Whatever else the Bernet, Baker and Adkins (2022) paper does or does not establish about US definitional consensus, the underlying behavioural pattern they describe is real and widespread in the UK as well.

• The UK legal authority is the FJC guidance, not US custody-evaluator opinion. A UK judge in the family court does not adjudicate a case by reference to the 80 percent agreement among US evaluators on Bernet-camp definitions. A UK judge applies the FJC three-element test under the welfare paramountcy principle of Children Act 1989 s.1 and Practice Direction 12J. The Bernet et al. paper is useful context for that decision, not authority.

Limits, Conflicts of Interest, and the 2024 Walk-Back

Three honest qualifications belong on every reading of this paper.

The methodological limits the authors largely acknowledge. The single-source professional listing, the one-round design, the pre-formulated definitions written by the authors, the absence of a comparison frame, and the small total n of 119 are all real limits. The authors themselves note “more research needs to be done” in the surrounding Bernet-camp literature. The paper is a snapshot of one professional subset, not a field-wide consensus measurement.

The conflict-of-interest disclosures. William Bernet is the founder and president of the Parental Alienation Study Group (PASG), receives royalties from Charles C Thomas Publisher for the Lorandos and Bernet (2020) textbook Parental Alienation — Science and Law, and has been paid as an expert witness in custody cases. Amy Baker has authored or co-authored most of the major parental-alienation measurement instruments — including the Baker Strategies Questionnaire and the Baker Alienation Questionnaire — and consults in private practice. These disclosures are present in the paper itself and should be present in any reading of it. They do not invalidate the work; they are the standard disclosures that allow readers to weight it appropriately.

The Garber, Simon, Bernet and Griffin (2024) walk-back. In January 2024, the Garber and Simon team that had written the 2023 “Looking Beyond the Sorting Hat” critique of the Five-Factor Model met with Bernet and Griffin to negotiate a shared position. The output, in Family Transitions, is the framing that “the Five-Factor Model is a good foundation but needs to be more fully developed and defined” — a partial walk-back of the strongest version of the consensus claim by senior figures including Bernet himself. The 2022 paper’s headline 80 percent figure has not been retracted, but the 2024 publication is the most relevant subsequent context for any reader who wants to know how the field has moved.

The most important methodological critic is Jean Mercer, professor emerita at Stockton University. Her published critiques include Mercer (2021) on the methodological problems in parental-alienation treatment research, and the book-length critique Mercer and Drew (2022) Challenging Parental Alienation (Routledge). Mercer’s argument applied to the 2022 paper is that a Likert-scale survey of practising evaluators on pre-formulated definitions — a frame self-selected to evaluators who already share the vocabulary — is not measuring whether the constructs are scientifically valid. It is measuring whether the practitioners endorse the wording.

The honest reading of Bernet, Baker and Adkins (2022) is the one this article tries to support. There is broad agreement on terminology among working US child custody evaluators on a specific professional listing, with an 88 percent response rate and roughly 80 percent endorsement of each of 11 definitions. That is real and it is the strongest available evidence of definitional consensus among that subset. It is not field-wide consensus, prevalence, validity, or ICD-11 / DSM-5 recognition. Read alongside Kline Pruett and colleagues (2023) and the Garber, Simon, Bernet and Griffin (2024) walk-back, the picture is layered evidence rather than settled consensus.

UK readers — and any reader thinking about how the paper applies to a real custody decision — should also read the FJC December 2024 guidance and the Hine 2025 UK prevalence study. The three papers — the US definitional consensus, the UK empirical floor, and the UK legal framework — are the cluster Love Over Exile is building up around the UK alienated parent in 2026. Each without the others is incomplete.