The new APS regulation changes the mission of APS from a casework focus of helping vulnerable adults to a focus on "perpetrators".  Certainly, those who abuse vulnerable adults should be treated as criminals by the criminal justice system--not protective services which has always focused on the victim.  I recommend removing the word "perpetrator" from the policy and regulation.  APS should not be burdened with any level of determination as to licensure of a facility nor of personnel decisions of any facility.  This regulation should not suggest that the APS assessment is a criminal or punitive process.  APS findings should remain focused on the victim's need for services and protection from subsequent abuse or neglect vs. focus on the perpetrator.  Criminalizing language does not take into account self neglect which comprises about half of APS situations, so this would create a confusing element in practice.

Determination of a perpetrator in turn creates a new process for appeal of findings of abuse or neglect.  This alone would require greater resources, not to mention any subsequent legal action brought by those for whom a finding is made.  The regulation should continue to emphasize good social work, assessment and services as the most productive means of protecting vulnerable adults.  

Thank you for the opportunity to comment.