As an APS Supervisor I would like to offer the following reflections and recommendations that I believe would strengthen practice and policy across the Commonwealth:

1. Clarification of the definition of "Incapacitated Person" as there is currently variation in how jurisdictions interpret and apply the definition of an incapacitated adult, largely due to the lack of specificity around what constitutes "sufficient understanding" and the ability to make a "responsible decision." Further clarification in the statute or guidance would support consistency in practice and decision making across agencies. 
2. Inclusion of Financial Institutions as Mandated Reporters-With financial exploitation on the rise, it would be highly beneficial to include all financial institutions--including banks, wealth management companies, investment firms, and trust agencies---as mandated reporters. Establishing a clear policy around the timely release of financial documentation to APS would improve our ability to investigate cases effectively and reduce delays that can impede protective interventions. 
3. Adjusting face to face timelines for financial exploitation cases-Unlike abuse or neglect cases, financial exploitation often requires substantial information gathering prior to the initial client visit. Extending the face to face time to up to 14 days for these cases--when there is no imminent physical risk---would allow for more thorough preparation and coordination, especially with law enforcement partners. This adjustment could improve both investigative accuracy and client outcomes. 
4. Reviewing disposition timeframes-The current 45 day standard for case disposition is appropriate for many cases, but financial exploitation investigations are uniquely time intensive. They often involve complex financial reviews, data reconciliation, and cooperation with external institutions. Extending the timeframe for these specific cases would allow APS workers to conduct more comprehensive and accurate investigations. 
5. Client Centered Flexibility in Alleged Perpetrator Notifications-The written notification to alleged perpetrators is a critical component of due process. However, in certain cases---particularly those involving family members where there is a risk of retaliation or where the client has expressed safety concerns--it would be helpful to have a policy option that allows for flexibility. Providing the ability to withhold notification in limited safety based circumstances could enhance client protection and promote long term stability in family based exploitation cases.

These recommendations are rooted in daily practice and information that is coming from the challenges our team faces in the field. Thank you.