Guardian Ad Litem and Hearsay

I finished up a trial today where I was the guardian ad litem.  I went back and looked at McDonald v. McDonald, 39 So.3d 868 (Miss. 2010) before the hearing.  From doing guardian ad litem work, this case is still hard to grasp.  Prior to this case, the common practice was to for a guardian ad litem to investigate issues of child custody, abuse, neglect, etc.,  file a report, and testify to the results and findings of the investigation, including hearsay, and make a recommendation.  McDonald however held that the statements made in a guardian ad litem report still have to qualify as an exception to the hearsay rule for that portion to come in.  As others have suggested, this essentially makes it where the guardian ad litem needs to be qualified as an expert by the Court pursuant to Rule 702 of the Mississippi Rules of Evidence in order to get a lot of these hearsay issues in since an expert can state the basis of their opinion which can rely on hearsay.  There is potentially one other avenue to look at that I did one a case last year.  The parties did an agreed order signed by all parties that allowed the guardian ad litem to testify about the results of her investigation and specifically stated that there would be no hearsay objection to it.  These are some issues to think about for your next trial.