The Greater Augusta Coalition Against Adult Abuse (GACAAA) is opposed to the proposed regulations to notify alleged perpetrators of abused adults of the disposition of the Adult Protective Services (APS) investigation as stated in 22VAC40-740-140(H). We are concerned that approval of  this regulation will unintentionally jeopardize the safety of  victims. These victims are vulnerable adults who  frequently live with or depend on the alleged perpetrator to provide for and take care of them. Notifying  the alleged perpetrator of the investigation places the alleged victim at greater risk of harm than already exists, as retaliation may occur.

The purpose of APS is to protect  elderly and disabled adults. If this regulation becomes policy,  language must be included to ensure the safety of the victims. I suggest the following language (changes shown in italics):

                                           H. The local department shall notify the alleged perpetrator................unless such  notice                                                       would pose a danger to the health, safety, and welfare of the alleged victim, as                                                 determined by the local agency executive director.

We do understand that the Commonwealth proposed these regulations to provide "due process" to the alleged perpetrators. However, there is no need to provide due process unless there has been a negative consequence as a result of the investigation. The APS disposition is whether or not the alleged victim needs services and accepts or refuses these services. However, if the alleged perpetrator were to be charged with a crime then perhaps they should be given the right to "due process". Thus, we propose the following language(changes shown in italics):

                                                    H. If the alleged perpetrator has been charged with a crime as a result of the                                                                      APS investigation,  the local department shall notify.......

In summary, GACAAA opposes these proposed regulations and recommends that they be deleted. However, if the State decides to approve these regulations, we ask that the changes we have suggested above be written into the policy to ensure the safety of the victims.

We appreciate the opportunity to comment on these regulations.

Anne See

Co-Chair

Greater Augusta Coalition Against Adult Abuse

www.GACAAA.com