My comments below:

• The history and mission of APS applies casework practices for at risk adults who need services to prevent or remove the risk.  APS workers assess the needs and determine services.
• Findings for investigations are focused on the need for services: (1) unfounded, (2) needs protective services and accepts, (3) needs protective services and refuses, (4) need for protective services no longer exists.  Not focused on criminalization or the "perpetrator".
• When the living situation is not a private home, licensing officials and administrators are informed about the referrals and the findings, but conducct their own invetigations.  APS workers do not make licensing or personnel decisions.
• Over the years, criminal legal terms, such as investigation, preponderance of evidence, and perpetrator have been injected into guidance policy.  The new regulation introduces "perpetrator" into regulation for the first time and then establishes the right to review.  The casework mission of APS is being confused and jeopardized by this change.
• No recognition that in cases of self-neglect, where the "victim" is the "perpetrator" comprises more than 50% of APS.
• Grave concerns that "perpetrators" will have access to presently confidential information.
• Contrary to Virginia Department of Social Services estimates, the League determined through a survey of local agencies the statewide costs in 2011 was $318,214.

These regulations change the fundamental mission from casework to focus on "perpetrators".  Such terms must be removed from policy guidance and regulation.