My comments are both as a provider of services and as an LHRC member.  I appreciate the Department wanting to streamline the process however, placing sole responsibility for oversight on the advocates/licensing is not feasible under the current system. The Dept has limited resources for both of these divisions and the current workload of each is unmanageable. In theory, the plan sounds workable but in reality it will only weaken an already fragile system.  Take a look at the existing number of advocates and divide that into the number of clients each advocate has responsibility to protect.  IT IS NOT POSSIBLE TO ASSURE AND PROTECT THE RIGHTS OF PEOPLE.

LHRC's serve a vital function of oversight which assists regional advocates in assuring the protection of rights to individuals receiving services.  As a provider, reporting to an LHRC, the fact that I am required to report to this Committee makes me more vigilant in assuring individual rights.  Knowing that there will  be scrutiny of my actions as a provider serves as a check and balance.  Removing this function from LHRC's will set this already fragile system backwards in protecting/and assuring  rights.  The proposal is to revamp the LHRC's functions and have the advocates handle all rights violations.  If adequate resources were available, this might be a good idea but at present some advocates are responsible for thousands of clients at any given time.  The LHRC's function to provide an additional layer of accountability in protecting a vulnerable  population.    The proposed diluting of this system runs counter to the Department of Justice requirements to assure health and safety.

As a provider of services, the proposed regulations would surely lighten some of the burden but it will do nothing to protect people.  The current system is hanging by a thread; the proposed regulations, if approved, will sever the one thread that holds this fragmented safetynet in place.  As an LHRC member, I do so because I believe I serve an important role in protecting people.  Having providers no longer report to this entity will place people at risk.  During every LHRC meeting I have seen the majority of providers want to do the right thing.  In those same meetings, I have seen providers ( though only a few) who have no interest in promoting rights.  They attend because presently they are required to do so. As a  provider and and LHRC member! I have learned a great deal from other providers.  I believe it has made me a better advocate.    To strip this important process from providers will only weaken an already struggling system of care.  Thank you for allowing me to comment on this important matter.