First, I agree fully with the comments posted anonymously on 5/22/23, especially those about the twenty four hour time frame being unnecessarily burdensome. As the author suggests, frequently given the nature of the settings and shifts that this work requires, 24 hours does not allow for a thorough and accurate internal review prior to reporting. 

In addition, the data and the narrative explanation provided at this time do not support the need for the change.  Using my experience with challenging consumers as a guide, a more likely reason that a small percentage of the "peer on peer" events are being found to be neglect is because these incidents are not neglect. Using your own definitions, the large majority of these events are not due to faults or errors by caretakers or their processes, intended or otherwise. Providers who accept clients with histories of aggressive behaviors and acting out are to be commended and supported in their work. When providers have clients with those proclivities, we work with them to make better choices, of course, but when they do not it is not necessarily because they have been intentionally neglected or some important aspect of their care has been missed. The underlying assumption here is highly problematic, and could very well lead to providers choosing not to provide services to those most in need.