concurring:
The principal issue presented is whether a mother whose parental rights were involuntarily terminated was wrongfully denied the effective assistance of counsel at the termination proceeding.1 I agree with the majority that a decree terminating parental rights may not be disturbed on appeal on the. basis of a parent’s ineffectiveness of counsel claim unless the performance of counsel affected the outcome of the termination proceeding. I also agree that the appellant in this case has failed to prove that she was prejudiced by any error or omission on her counsel’s part. Accordingly, I concur in the result reached by the majority. I write separately, however, since I differ with some aspects of the majority’s legal analysis.
S.F., the appellant in this case, had persistent problems with drug addiction that interfered with her ability to raise her daughter T.M.F. In light of S.F.’s failure to respond to drug treatment programs, the Montgomery County Office *625of Children and Youth Services (OC & Y) filed a petition for the involuntary termination of S.F.’s parental rights. At the hearing on the petition, S.F. was represented by an attorney from the Montgomery County Legal Aid Service. On January 21, 1988, the court entered a decree nisi terminating S.F.’s rights to T.M.F. S.F. then obtained private counsel who filed exceptions specifically challenging the effectiveness of the Legal Aid attorney. On August 9, 1988, the court denied the exceptions and entered a final termination order. Private counsel then filed this timely direct appeal.
We must consider a challenge to the effectiveness of trial counsel raised on direct appeal from an order terminating parental rights. This case does not involve a collateral attack on a parental termination order. Nor does this case involve an application of the right to effective assistance of counsel to juvenile delinquency proceedings. The majority’s discussion of the writ of habeas corpus as well as the majority’s commentary regarding the rights of juveniles is obiter dictum. I would defer consideration of these matters until they are squarely presented for review.
Turning to the issue at hand, appellant maintains that her former attorney did not provide effective assistance at the parental termination proceeding. In order to evaluate this claim, it is necessary to conduct a three part inquiry. First, does a parent have a right to counsel at a termination proceeding? If so, does this right to counsel entail a right to have counsel render effective assistance? Moreover, if effective assistance is required, what standard should be used to determine whether counsel’s performance has been so poor as to justify vacating a termination decree? Only after considering these preliminary questions can we decide whether appellant is entitled to relief.
I.
The starting point for an analysis of the right to legal representation in termination proceedings is the text of the Adoption Act. 23 Pa.Cons.Stat.Ann. §§ 2101-2910 (Purdon *626Supp.1989). Section 2313 states: “The court shall appoint counsel to represent the child in an involuntary termination proceeding when the proceeding is being contested by one or both of the parents.” Thus, children in contested termination proceedings have a clear statutory right to the appointment of counsel. Barclay v. Barclay, 367 Pa.Super. 529, 536, 533 A.2d 143, 147 (1987). However, the Act, does not extend this guarantee to indigent parents. The only reference to counsel for parents can be found in the portion of the Act that deals with notice of the hearing on the termination petition. The Act provides:
At least ten days’ notice shall be given to the parent or parents, putative parents, or parent of a minor parent whose rights are to be terminated____ The notice shall state the following:
“A petition has been filed asking the court to put an end to all rights you have to your child (insert name of child). The court has set a hearing to consider ending your rights to your child____ You have a right to be represented at the hearing by a lawyer. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help.
(Name).. ................................
(Address)...............................
(Telephone number)................... ”
23 Pa.Cons.Stat.Ann. § 2513(b).
Section 2513(b) indicates that parents have a right to obtain counsel by their own efforts and to bring this counsel with them to the termination hearing. This section does not mandate that the court itself appoint or provide counsel for the parent, nor does it create an obligation on the part of the state to ensure that counsel is available.2 Thus, *627Pennsylvania law does not provide a statutory basis for relief where proper notice has been given to the parent but the parent has been unable to secure legal representation. One must therefore consider whether an uncounseled termination of parental rights would offend constitutional principles.
The leading case on the constitutional question in this Commonwealth is In re: Adoption of R.I., 455 Pa. 29, 312 A.2d 601 (1973). In Adoption of R.I., the natural mother did not have access to counsel at the time of the termination hearing. On appeal from a final decree terminating her parental rights, the Pennsylvania Supreme Court unanimously concluded that indigent parents have a right to the appointment of free counsel. In reaching this decision, the Court did not conduct a particularized examination of the natural mother’s need for legal assistance. The Court instead stressed the vital importance of the right to counsel in all involuntary termination proceedings:
In has long been established that an individual is entitled to counsel at any proceeding which may lead to the deprivation of “substantial rights.” Coleman v. Alabama, 399 U.S. 1 [90 S.Ct. 1999, 26 L.Ed.2d 387] (1970), In re: Gault, 387 U.S. 1 [87 S.Ct. 1428, 18 L.Ed.2d 527] (1967), United States v. Wade, 388 U.S. 218 [87 S.Ct. 1926, 18 L.Ed.2d 1149] (1967), Miranda v. Arizona, 384 U.S. 436 [86 S.Ct. 1602, 16 L.Ed.2d 694] (1966), Com. ex rel. Rambeau v. Collins, 455 Pa. 8, 314 A.2d 842 (1973). Commonwealth v. Johnson, 428 Pa. 210, 236 A.2d 805 (1968) . While the above-cited cases are criminal in nature, the logic behind them is equally applicable to a case involving an indigent parent faced with the loss of her child. In the words of the Court of Appeals of New York, which reached the same conclusions in the Matter of Ella R.B. [30 N.Y.2d 352, 334 N.Y.S.2d 133, 136], 285 N.E.2d 288, 290 (1972): “A parent’s concern for the liberty of the child, as well as for his care and control, *628involves too fundamental an interest and right [citing cases] to be relinquished to the State without the opportunity for a hearing, with assigned counsel if the parent lacks the means to retain a lawyer. To deny legal assistance under such circumstances would — as the courts of other jurisdictions have already held [citing cases] — constitute a violation of his due process rights and, in light of the express statutory provision for legal representation for those who can afford it, a denial of equal representation of the laws as well. As the Federal District Court wrote in the very similar Cleaver case [Cleaver v. Wilcox, decided March 22, 1972 (40 U.S.L.W. 2658) ], ‘whether the proceeding be labelled “civil” or “criminal,” it is fundamentally unfair, and a denial of due process of law for the state to seek removal of the child from an indigent parent without according the parent the right to the assistance of court-appointed and compensated counsel ... Since the state is the adversary ... there is a gross inherent imbalance of experience between the parties if the parents are not represented by counsel. The parent’s interest in the liberty of the child, in his care and in his control, has long been recognized as a fundamental interest ... Such an interest may not be curtailed by the state without a meaningful opportunity to be heard, which in these circumstances includes the assistance of counsel.’ ”
In the instant case ... appellees are attempting to terminate appellant’s parental rights against her opposition. Consequently, the appellant’s adversaries have the burden of proving that they are entitled by law to terminate those rights. In such a proceeding, it would be grossly unfair to force appellant to defend against the appellee’s case without the assistance of someone, trained in the law, who could test the appellees’ case by the rules of evidence and the techniques of cross-examination.
455 Pa. at 31-33, 312 A.2d at 602-03.
In the sixteen years since Adoption of R.I. was decided, counsel for indigent parents have routinely participated in *629involuntary termination hearings in this state. However, subsequent legal developments have called into question the precedential value of the Adoption of R.I. decision. In Lassiter v. Department of Social Services, 452 U.S. 18, 101 S.Ct. 2153, 68 L.Ed.2d 640 (1981), a sharply divided United States Supreme Court held that the federal Constitution does not require the appointment of counsel in every involuntary termination proceeding.3 The Lassiter majority implicitly acknowledged that a parent’s freedom to associate with her child is a form of liberty protected by the due process clause of the fourteenth amendment. See Santosky v. Kramer, 455 U.S. 745, 753, 102 S.Ct. 1388, 1394, 71 L.Ed.2d 599 (1982). However, the majority emphasized that parental termination proceedings do not directly result in the loss of the parent’s freedom from physical confinement. 452 U.S. at 25-26, 101 S.Ct. at 2158-59. The majority therefore established a presumption against the right to counsel in termination cases. This presumption may be overcome in particular instances where the parent’s interest in having counsel is at its strongest, the state’s interest in proceeding without counsel for the parent is at its weakest, and the risk that the denial of counsel will lead to an erroneous court decision is at its peak. 452 U.S. at 31, 101 S.Ct. at 2161. In other cases, the absence of counsel is “minimally tolerable under the [federal] Constitution.” 452 U.S. at 33, 101 S.Ct. at 2163.
Lassiter has undermined Adoption of R.I., at least insofar as Adoption of R.I. ’s broad right to counsel holding was based on the federal due process clause. It is unclear, however, whether Adoption of R.I. was decided solely on federal grounds. This court has previously suggested that Adoption of R.I. could be viewed as a state constitutional law decision. Corra v. Coll, 305 Pa.Super. 179, 187 n. 7, 451 A.2d 480, 485 n. 7 (1982). I would find that the *630Pennsylvania Constitution provides an adequate and independent basis for extending the right to appointed counsel in involuntary termination proceedings to all indigent parents. Cf. In re T.R., 502 Pa. 165, 465 A.2d 642 (1983) (Pennsylvania law provides independent basis for requirement that state must produce clear and convincing evidence in order to terminate parental rights); V.F. v. State, 666 P.2d 42 (Alaska 1983) (recognizing right to counsel in termination proceedings under Alaska Constitution). See generally Annotation, Right of Indigent Parent to Appointed Counsel in Proceeding for Involuntary Termination of Parental Rights, 80 ALR 3d 1141 (1977) (collecting state constitutional law authorities).
Although the Pennsylvania Constitution does not explicitly refer to due process, “it has been recognized that Article I, sections 1, 9, and 26 combine to provide the counterpart of the federal due process and equal protection provisions.” Gondelman v. Commonwealth, 520 Pa. 451, 466 n. 11, 554 A.2d 896, 903 n. 11 (1989), cert. denied, — U.S.-, 110 S.Ct. 146, 107 L.Ed.2d 105 (1989). Article 1, section 9 concerns the rights of the accused in criminal prosecutions, and article 1, section 26 concerns the right of the people to be free from discrimination in the exercise of their civil rights. The provision that deals most directly with fundamental fairness in the context of civil proceedings is article 1, section 1 which provides:
Section 1. Inherent rights of mankind
All men are born equally free and independent, and have certain inherent and indefeasible rights, among which are those of enjoying and defending life and liberty, of acquiring, possessing and protecting property and reputation, and of pursuing their own happiness.
I have little difficulty in concluding that among these inherent rights is the right of a parent to enjoy the companionship of her child. As we recently noted in In re Coast, 385 Pa.Super. 450, 561 A.2d 762 (1989) (en banc):
The family is an institution which preceded governments. Its sanctity was universally recognized before *631judges or statutes or constitutions or welfare organizations were known to man. The right of a child to a mother and a mother to a child are rights created by natural law. They are rights attributable to the nature of mankind rather than to enactments of law.
Id., 385 Pa.Superior Ct. at 464, 561 A.2d at 769 (citing In re Rinker, 180 Pa.Super. 143, 147, 117 A.2d 780, 783 (1955)).
One must therefore determine under what circumstances the state may deprive the parent of her article 1, section 1 right to the child. In reaching this determination, we are not bound by Lassiter since the provisions of the state constitution may provide greater protection than their federal counterparts. E.g., Commonwealth v. DeJohn, 486 Pa. 32, 403 A.2d 1283 (1979), cert. denied, 444 U.S. 1032, 100 S.Ct. 704, 62 L.Ed.2d 668 (1980); Corra v. Coll, 305 Pa.Super. at 179, n. 7, 451 A.2d at 485 n. 7. This is not to say that the decision to depart from a federal constitutional standard is one that may be taken lightly. I conclude, however, that an extra measure of protection for parents who are subject to termination proceedings is justified for three reasons.
First, the interest that a parent has in the care and companionship of her child is qualitatively different from the interests that are implicated in most other civil proceedings. What is at stake is not a mere property right but the right to maintain what will often be the most important relationship in a person’s life. Moreover, termination does not involve a temporary or limited interference with the parent’s freedom to associate with the child; “[termination of parental rights is the death sentence to a parent-child relationship.” In re Coast, 385 Pa.Super. at 483, 561 A.2d at 778 (Tamilia, J., concurring). It is true that a termination decree will not directly result in the loss of the parent’s own freedom from physical confinement. Yet, I have no doubt that vast numbers of parents would far prefer to serve a term of imprisonment than have their children taken from them and adopted by others. Accordingly, it does not seem fair to begin an analysis of the right to counsel in termi*632nation proceedings by applying a heavy presumption that no such right exists. Such an approach is insensitive to the unique nature of the injury caused by the loss of a child.
Second, when interpreting our state constitution, we should bear in mind the experience of the people and institutions of this Commonwealth as it relates to the subject at hand. In the years since Adoption of R.I. was decided, our family courts have proceeded on the assumption that counsel for parents in involuntary termination proceedings is constitutionally required. The appointment of counsel for the parent is now a customary part of termination proceedings and our state child service agencies have adjusted to the burden of seeking termination decrees in an adversary setting. Thus, it would be difficult to argue that the state’s interest in opposing the appointment of counsel is a strong one.4 Moreover, it is likely that failing to appoint counsel would run contrary to a widespread perception that legal representation in termination proceedings is a fundamental entitlement.
Third, a bright line rule that counsel is required in involuntary termination cases would promote fairness and judicial economy. The problems posed by a case-specific test for the right to counsel were thoughtfully explored by Justice Blackmun in his dissenting opinion in Lassiter:
[T]he case-by-case approach advanced by the Court ... entails serious dangers for the interests at stake and the general administration of justice. The Court assumes that a review of the record will establish whether a defendant, proceeding without counsel, has suffered an unfair disadvantage. But in the ordinary case, this simply is not so. The pleadings and transcript of an uncounseled termination proceeding at most will show the obvious blunders and omissions of the defendant parent. *633Determining the difference legal representation would have made becomes possible only through imagination, investigation, and legal research focused on the particular case. Even if the reviewing court can embark on such an enterprise in each case, it might be hard pressed to discern the significance of failures to challenge the State’s evidence or to develop a satisfactory defense. Such failures, however, often cut to the essence of the fairness of the trial, and a court’s inability to compensate for them effectively eviscerates the presumption of innocence. Because the parent acting pro se is even more likely to be unaware of controlling legal standards and practices, and unskilled in garnering relevant facts, it is difficult, if not impossible, to conclude that the typical case has been adequately presented. Cf. Betts v. Brady, 316 U.S. [455], at 476 [62 S.Ct. 1252, 1263], 86 L.Ed 1595 (1942) (dissenting opinion).
452 U.S. at 50-51, 101 S.Ct. at 2171-72 (Blackmun, J., dissenting).5
For all of the above reasons, I would adhere to the policy enunciated by the Pennsylvania Supreme Court in Adoption of R.I., supra. I would find that in this Commonwealth all parents have a constitutional right to be represented by counsel in involuntary termination proceedings.
II.
Since parents do have a right to counsel in involuntary termination proceedings, we must begin to define the scope and content of this right. In criminal cases, “[i]t has long been recognized that the right to counsel is the right to the *634effective assistance of counsel.” McMann v. Richardson, 397 U.S. 759, 771 n. 14, 90 S.Ct. 1441, 1449 n. 14, 25 L.Ed.2d 763 (1970). It is true that in the criminal context, the right to counsel is grounded in the sixth amendment, a constitutional provision that does not apply to civil proceedings. Yet, the policy behind reviewing the effectiveness of counsel’s performance does not depend on the precise textual source of the right to counsel. The reason for insisting that counsel perform in a competent manner stems from the realization that extending a right to secure court appointment of anyone other than an effective counsel would be a hollow gesture. See In re Hutchinson, 500 Pa. 152, 454 A.2d 1008 (1982) (interpreting Mental Health Procedures Act as guaranteeing right to effective assistance of counsel in civil commitment proceedings); Banks v. Randle, 337 Pa.Super. 197, 486 A.2d 974 (1984) (interpreting due process clause of fourteenth amendment as guaranteeing right to effective assistance of counsel for defendants in paternity actions).
Only an effective advocate can perceptively cross-examine witnesses, cogently argue a client’s position to the trial judge, or take other action necessary to ensure a fair hearing for the client. Unless counsel for parents in termination proceedings are held to a minimum level of competence, the parent’s right to counsel would be nothing more than a right to be accompanied into court by an individual who may be utterly incapable of defending his client’s interests. I would therefore find that the state constitutional right to counsel in termination proceedings encompasses a right to the effective assistance of counsel.
III.
We must next consider under what circumstances the right to the effective assistance of counsel in termination proceedings would be violated. In other words, when would a poor performance by parent’s counsel provide a sufficient basis for vacating a parental termination order and remanding for a new termination hearing? In answering this *635question, it is useful to consult the standard for ineffective assistance of counsel that has developed within the context of criminal appeals. However, as the majority emphasizes, it is also important to bear in mind the significant differences between a parental termination hearing and a criminal trial.
The test for determining whether a criminal defense attorney has provided effective representation is familiar to the bench and the bar. As the Pennsylvania Supreme Court recently noted:
We have taken great pains to set forth the criteria that must be established when one attempts to assert the ineffectiveness of counsel. The threshold inquiry in such claims is whether the issue/argument/tactic which counsel has foregone and which forms the basis for the assertion of ineffectiveness is of arguable merit; for counsel cannot be considered ineffective for failing to assert a meritless claim. Commonwealth v. Pursell, 508 Pa. 212, 495 A.2d 183 (1985). If this threshold is met, it must next be established that the particular course chosen by counsel had no reasonable basis designed to effectuate his client’s interest. Commonwealth ex rel. Washington v. Maroney, 427 Pa. 599, 235 A.2d 349 (1967). Finally, we require that the defendant establish how counsel’s commission or omission prejudiced him. Commonwealth v. Pierce, 515 Pa. 153, 527 A.2d 973 (1987).
In making assertions of ineffectiveness, we also require that an offer of proof be made alleging sufficient facts upon which a reviewing court can conclude that trial counsel may have, in fact, been ineffective. This is so because we frown upon considering claims of ineffectiveness of counsel in a vacuum. Commonwealth v. Pettus, 492 Pa. 558, 424 A.2d 1332 (1981).
Commonwealth v. Durst, 522 Pa. 2, 5, 559 A.2d 504, 505 (1989).
This language highlights certain minimal requirements for establishing ineffective assistance of counsel that should also apply to appeals from parental termination *636orders. Clearly, counsel for the parent could not be found ineffective for failing to assert a meritless claim at the termination hearing, or for choosing a course of conduct reasonably designed to effectuate the parent’s best interest, or for taking or failing to take any action that did not prejudice the parent. Nor could counsel be found ineffective if the parent failed to come forward with a sufficient offer of proof regarding counsel’s incompetent representation. Thus, the ineffectiveness analysis in parental termination cases is in many respects similar to the ineffectiveness analysis in criminal cases.
This does not mean, however, that the analysis undertaken in both types of cases should be identical. A termination hearing is not simply a contest between the parent and the state; the result of the hearing has a direct, profound, and inevitable effect upon a third party — the child. Once parental rights are terminated, the child will be removed from the parent’s custody and control and placed in a new family environment. The child will usually form strong bonds to her new adoptive parents, or to foster parents or other caretakers as the case may be. The more stable the new environment, the more likely that the child will successfully overcome the trauma associated with the termination proceedings. Thus, a decision to reverse a decree of termination and remand for a new hearing may seriously jeopardize the child’s psychological and emotional well-being.
In light of the unique impact that termination will have on the life of the child, the Commonwealth has a powerful interest in preserving the finality of a parental termination decree.6 This extraordinary need for finality distinguishes parental termination proceedings from criminal proceedings as well as from nearly all other civil proceedings. Accord*637ingly, there is good cause for applying a more stringent test for measuring the effectiveness of parent’s counsel in termination proceedings than for measuring the effectiveness of lawyers representing clients in other settings. I would therefore restrict relief in termination cases to instances in which a parent makes a strong showing of ineffective assistance of counsel. The parent should come forward with evidence that indicates that a high degree of likelihood exists that but for an unprofessional error on counsel’s part, parental rights would not have been terminated.7
These observations are consistent with the “fundamental fairness” test for ineffectiveness of counsel proposed by the majority. Majority Op. at 615-616. I agree with the majority that upon review of an ineffectiveness claim, an appellate court must focus squarely on whether “any failure of [counsel’s] stewardship was the cause of the decree of termination.” Id. However, I see no reason why an allegation of ineffectiveness of counsel should automatically “result in a review by this Court of the total record with a determination to be made whether on the whole, the parties received a fair hearing, [and] the proof supports the decree by the standard of clear and convincing evidence.” Id. If a parent wishes this court to review the sufficiency of the evidence supporting the termination decree, the parent should raise a separate challenge to the sufficiency of the evidence.
The issue of whether the termination decree is supported by sufficient evidence should not be confused with the issue of whether trial counsel has been ineffective. Wholly apart from any consideration of ineffectiveness of counsel, it is well established that an appellate court must vacate a *638termination order where there is insufficient evidentiary support for the trial court’s findings. See, e.g., In re T.L.G., 351 Pa.Super. 256, 505 A.2d 628 (1986). In order for the evidence to be sufficient, the trial court must have reasonably concluded that the elements of the parental termination statute have been established by clear and convincing evidence. See Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982); Baby Boy A. v. Catholic Social Services, 512 Pa. 517, 517 A.2d 1244 (1986). Accordingly, if a termination decree is not supported by clear and convincing evidence, this court may ordinarily grant relief without undertaking an analysis of counsel’s performance.
Claims of ineffective assistance will usually come into play in cases where there is competent evidence from which a judge could conclude that termination of parental rights is mandated by statute. The majority suggests that under such circumstances, ineffective assistance of counsel would never provide a basis for affording the parent relief. See Majority Op. at 606. I disagree. Ineffective assistance of counsel may be difficult to establish but it should not be impossible to do so. Suppose, for example, that the trial court determined that parental rights could be terminated because counsel failed to impeach the witnesses who testified against the parent. Or suppose that counsel neglected to present conflicting evidence that strongly bolstered a parent’s claim that she had not neglected her children. In such cases, justice requires that the parent have an opportunity to prove that the outcome, of the termination proceeding was the result of counsel’s incompetence. Cf. In re Manuel, 566 A.2d 626, 629 n. 7 (Pa.Super.1989) (denial of right to counsel in dependency proceeding requires remand despite sufficiency of evidence supporting trial court order since “evidence below was completely one-sided”).
In the case sub judice, however, appellant has clearly failed to carry her burden of proof. In her brief to this court, appellant claims that her attorney should have asked her mother, her drug counselor, and other unspecified wit*639nesses to testify at the termination hearing that she had made progress in recovering from her drug dependency. Appellant also faults counsel for failing to inform the court that her alleged difficulty in gaining admission to a drug detoxification program in 1987 contributed to her subsequent addiction problems. Yet, in light of appellant’s unsuccessful experiences with numerous drug treatment programs, and her history of neglecting the needs and welfare of her daughter, it is difficult to imagine that counsel’s purported omissions were of crucial importance. There is every reason to believe that appellant’s rights would have been terminated even if counsel had called additional witnesses or presented additional evidence. For the above-stated reasons, I respectfully concur in the result reached by the majority.
. The mother also argues on appeal that the order terminating her parental rights was not supported by clear and convincing evidence. As the majority concludes, this claim is without merit.
. Nor does the Judiciary and Judicial Procedure Code require court appointment of counsel in termination proceedings. The Code simply states: "In all civil matters before any tribunal every litigant shall have a right to be heard, by himself and his counsel, or by either of *627them." 42 Pa.Cons.Stat.Ann. § 2501(a) (Purdon 1981). This language has never been interpreted as granting civil litigants the same right to appointed counsel enjoyed by defendants in criminal prosecutions.
. Four dissenting justices would have recognized a federal constitutional right to counsel in all involuntary termination cases. See 452 U.S. at 35-59, 101 S.Ct. at 2163-76 (Blackmun, J., dissenting, joined by Brennan, J. and Marshall, J.) and 452 U.S. at 59-60, 101 S.Ct. at 2176 (Stevens, J., dissenting).
. The state does have a powerful interest in ensuring that termination decrees are not routinely disturbed on appeal on the ground that the natural parent was denied the right to legal representation. However, this interest may be taken into account when reviewing legal challenges to the performance of the parent’s appointed counsel. See section III, infra.
. Justice Blackmun added in a footnote:
Of course, the case-by-case approach announced by the Court today places an even heavier burden on the trial court, which will be required to determine in advance what difference legal representation might make. A trial judge will be obligated to examine the State’s documentary and testimonial evidence well before the hearing so as to reach an informed decision about the need for counsel in time to allow adequate preparation of the parent’s case.
452 U.S. at 51 n. 19, 101 S.Ct. at 2172 n. 19.
. Of course, a parental termination order must be vacated if the decree is not supported by clear and convincing evidence. Santosky v. Kramer, 455 U.S. 745, 102 S.Ct. 1388, 71 L.Ed.2d 599 (1982). The Commonwealth's interest in finality is strengthened where the family court has properly applied the clear and convincing evidence standard before entering the termination order.
. In criminal cases, the defendant must also prove that he was prejudiced by counsel’s deficient performance. However, the defendant need only establish a "reasonable probability that, but for counsel’s unprofessional errors, the result of the proceedings would have been different.” Commonwealth v. Groff, 378 Pa. 353, 374 n. 11, 548 A.2d 1237, 1247 n. 11 (citing Strickland v. Washington, 466 U.S. 668, 693-694, 104 S.Ct. 2052, 2067-68, 80 L.Ed.2d 674 (1984)). "[The] defendant need not show that counsel’s deficient performance more likely than not altered the outcome of the case.” Id.