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.

As a current APS worker, I would like to see the following changes, 

1. I would like to propose extending the current 45-day disposition timeline for financial exploitation cases, as the complexity and volume of data required for thorough investigation often necessitate additional time.
2. I would like to propose that the Right to Review letter be made optional in cases where there are concerns that notifying the alleged perpetrator may lead to retaliation against the client, thereby compromising their safety.
3.  I would like to propose that, in scam cases, the perpetrator screening form in Peerplace include automatically selected checkboxes when the perpetrator’s information is unknown, to ensure consistency and efficiency in documentation. 

Thank you for your consideration for this matter. 

1. Notification dates at the close of investigations should be unified.  The reporter letter, right to review letter, and referrals should be completed within 15 calendar days of certification.  The registration closed date should be 30 days after the date of certification.  This would reduce confusion and result in a more efficient process.
2. Currently, investigations must be completed in 45 calendar days of receipt.  There has been a significant increase in financial exploitation cases.  Many of these require documentation from the bank and other sources.  There is currently not enough time allocated to investigate, gather the documents, and make a disposition.  This policy was set prior to the addition of the right to review process and was developed to uphold the rights of the adult client.  More thorough investigation is required for the purpose of upholding the rights of the alleged perpetrator in right to review cases.  It is proposed that financial exploitation cases and joint investigations with law enforcement should be completed within 90 calendar days of receipt.
3. The purpose of interviewing the client is to determine if protective services are needed.  The current right to review process does not align with this policy.  The purpose of the investigation, interviews, and the right to review process need to be consistent.  The current role of APS is not just to protect the adult but is also to ensure due process for alleged perpetrators and it should be reflected as such.  Current policy was written to reflect the needs and safety of the adult and does not put emphasis on the alleged perpetrator, the potential prosecution, or the rights of the alleged perpetrator.
4. Policy is needed to reflect the circumstances where cases can be closed early (such as the death of a client, permanent removal of risk, etc.) OR policy needs to state that under no circumstances can a case be closed early. There is currently no policy or guidance on this issue.