In New York ex rel. N.Y. State Off. of Children & Family Servs. v. United State Dept. of Health & Human Services' Admin. for Children & Families (556 F3d 90 [2nd Cir 2009]) the United States Court of Appeals held that the statutory definition of "reasonable efforts," as expanded by enactment of the Adoption and Safe Families Act, unambiguously incorporated into the statute a condition of foster care maintenance reimbursement on a judicial determination that reasonable efforts were made with respect to the child.