Action | Amend Adult Protective Services |
Stage | Proposed |
Comment Period | Ended on 11/23/2012 |
Dear Sir or Madam:
I am writing as the Director of Campbell County Department of Social Services to express concerns in regard to the revisions to the Adult Protective Services Regulation, 22VAC40-700, now posted in the Virginia Regulatory Town Hall for public comment. I have concerns related to the sections pertaining to notifications to alleged “perpetrators” and the right of “perpetrators” to request a review of the local agency’s investigative findings. The proposed regulation mistakenly implies that the APS assessment is a criminal or punitive process. A summary about APS and concerns about the proposed regulation is below:
The new APS regulation changes the mission of APS from a casework focus of helping vulnerable adults to a focus upon “perpetrators”. Instead of going in a direction of further “criminalizing” Adult Protective Services, it is recommended that “perpetrators” and other like terms be removed from policy guidance and regulation. The function of Adult Protective Services can be maintained through policy and regulation emphasis upon the APS worker’s role of assessment of the need for services for vulnerable adults and the requirement for referral to licensing, regulatory and legal authorities. Vulnerable adults can live safely in their homes and in facilities with the partnership functions of APS workers and those with legal, regulatory, and personnel authority.
Sincerely,
Richard M. Verilla
Director