The history and mission of APS applies casework practices to situations involving older adults and incapacitated adults who are at risk. Findings for investigatons are focused on the need for services for the adult. When the living situation for the adult is not a private home, licensing officials and administrators are informed about the referrals and the findings. Licensing officials and administrators conduct their own investigations. APS workers do not make licensing or personnel decisions. Section C of 63.2-105 requires that APS "refer any appropriate matter, all relevant documentation to the appropriate licensing, regulatory, or legal authority for administrative action or criminal investigation." Over the years, criminal legal terms have been injected into guidance policy. The proposed regulation introduces "perpetrator" into regulation for the first time and then establishes the right to review. This confuses and jeopardizes the casework mission of APS. There will be unintended consequences with "perpetrators" having access to previously confidential information. There may be an increase in risk for vulnerable adults who live with and/or are dependent upon the "perpetrators". More than 50% of APS cases are situations of self-neglect in which the "perpetrator" is also the "victim". A fiscal analysis by the League found a state annual impact of at least $318,214. Criminal terms and processes should be removed from guidance and regulation.  The focus of APS should be on assessments and services.Joint investigations with licensing, regulatory, and administrative staff for those living in facilities or participating in day or transportation services provides "due process" for those "perpetrators" whose behavior results in personnel or licensing actions.