APS due process for alleged perpetrators of adult abuse or neglect is unnecessary, contrary to the purpose of the regulation and potentially harmful to the indiviudals the regulation protects.  Child protection traveled a simliar damaging path before instituting differential response.  1.  In no other part of the APS regulation is there mention of alleged perpetrators.  "Perpetrator" is taken from guidance from VDSS which is equally unecessary. APS takes no action except to report allegations as required.  Administrative or civil actionsor criminal prosecutions are taken by law enforcement, licensing, or employers are based upon investigation, not the determination of  APS that a client needs or needed services. 2. APS regulation is not designed to take action against any individual who may be responsible for abuse or neglect of an adult.  It is designed to find whether a client needs or needed services and to provide services to protect vulnerable adults.  A requirement to name a perpetrator (essential to providing alleged perpetrators with due process) is contrary to that purpose in that it changes the focus from mitigating the circumstances endangering the adult to gathering evidence to establish a case.  Most reports and findings involve self- neglect; the implications are obvious.  3. A significant percent of remaining "needs services" cases involve family members as caretakers. Adult victims often are averse to negative actions against family members.  This requirement could reduce reporting and cooperation of victims and their families.