Appendix 3 

Report on the Updates to the Voluntary 

Consensus Guidelines for APS Systems 

September 23, 2019 

Prepared for 

Administration for Community Living 

Offce of Performance and Evaluation 

Submitted by 

New Editions Consulting, Inc. 

The Lewin Group 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 

Abbreviations 

AAA Area Agency on Aging 

ACL Administration for Community Living 

APS Adult protective services 

CSA Child sexual abuse 

DHHS Department of Health and Human Services 

Guidelines National Voluntary Consensus Guidelines for State APS Systems 

LTCO Long-term Care Ombudsman 

MDT Multidisciplinary team 

NAMRS National Adult Maltreatment Reporting System 

NAPSA National Adult Protective Services Association 

NCEA National Center on Elder Abuse 

OAA Older Americans Act 

QA Quality assurance 

RFI Request for information 

SLTCO State Long-term Care Ombudsman 

SLTCOP State Long-term Care Ombudsman Program 

TEP Technical expert panel 

2 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 

Contents 

Abbreviations 2 

Introduction 4 

Objectives and Methods 5 

1. Literature Search and Review 5 

Purpose 5 

Methods 5 

Results 6 

2. Development of Proposed Updates 11 

3. Stakeholder Engagement 11 

Public Comment Period 11 

Stakeholder Webinars 12 

4. Analyses of Stakeholder Feedback 12 

Quantitative Analysis 12 

Qualitative Analysis 12 

5. Stakeholder Feedback Analyses: Results 13 

Quantitative Results 13 

Qualitative Results 18 

6. Technical Expert Panel 35 

Purpose 35 

Methods 35 

Results 36 

7. Considerations and Recommendations for Future Updates 38 

Appendix A. List of Domains and Elements 39 

Appendix B. Technical Expert Panel 40 

Appendix C. Included Articles in Updates by Guidelines Domain/Element 41 

Appendix D. Verbatim Public Comments by Domain and Elements 45 

Domain 1. Program Administration 45 

Domain 2. Time Frames 49 

Domain 3. Receiving Reports of Maltreatment 51 

Domain 4. Conducting the Investigation 51 

Domain 5. Service Planning and Service Implementation 52 

Domain 6. Training 56 

Domain 7. APS Program Performance 59 

3 
4 Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems

Introduction 

Adult protective services (APS) programs are state-run social services programs that are not subject to 

federal rules and regulations. As a result, each state has designed its own unique system. In addition, 

there is no single funding stream for APS, forcing states to look to multiple sources for funding and often 

leaving them with inadequate resources for their APS programs. Data from state APS agencies show an 

increasing trend in reports of maltreatment and increasing caseloads for APS workers, however.1 All of 

these challenges can present signifcant obstacles to responding in an effective and timely way to reports 

of abuse, neglect, self-neglect, and fnancial exploitation of older adults and adults with disabilities 

(hereinafter referred to as “adult maltreatment”). 

To support APS programs, it is more important than ever to demonstrate the effectiveness of APS programs and 

practices in improving client outcomes and provide states with tools to support effective and timely responses 

to adult maltreatment. To address this need, the Administration for Community Living (ACL) facilitated the 

development of the National Voluntary Consensus Guidelines for State APS Systems (Guidelines) in 2016 to 

provide the APS feld with guidance about effective APS practices. As part of the development, ACL applied

the Offce of Management and Budget (2016)2 and National Institute of Standards and Technology (2001)3 

process for creating feld-developed, consensus-driven guidelines. To eliminate unnecessary duplication and 

complexity in the development and promulgation of the Guidelines, ACL’s process remains consistent with 

the guidance of the National Institutes of Standards and Technology 15 CFR Part 287 (2020)4. 

To establish an evidence base for the 2016 Guidelines, ACL applied a multistep approach, with the frst step 

being the review of best practices and research from studies published between 2004 and March 2014. 

Given the paucity of peer-reviewed research on APS practices during that timeframe, ACL also reviewed key 

materials from other credible sources, including child welfare and the National Adult Protective Services 

Association (NAPSA). ACL then engaged expert working groups and stakeholders from the feld to draft, 

review, and refne the Guidelines, based on the available evidence as well as experiences from the feld. 

The resulting Guidelines consisted of seven broad domains (or topics) and several elements (or subtopics) 

for all but one of the domains. Each element consists of a background section and the actual guidance 

statements. For the list of the Guidelines’ domains and elements, see Appendix A. 

In 2018, ACL initiated the updates of the Guidelines to incorporate new research fndings and new areas of 

interest in APS practices and policies, following the same process for creating feld-developed, consensusdriven guidelines. The purpose of this report is to provide an overview of the process for updating the 

Guidelines, including the methods for obtaining feedback from the public and a technical expert panel 

(TEP; for a list of the TEP members, see Appendix B) and analyzing their feedback as well as the results 

from the analyses. To see the updated Guidelines, go to: https://acl.gov/programs/elder-justice/finalvoluntary-consensus-guidelines-state-aps-systems.

1 

 Teaster, P. B., Dugar, T., Mendiondo, M., Abner, E. L., Cecil, K. A., & Otto, J. M. (2006.) The 2004 Survey of Adult Protective 

Services: Abuse of vulnerable adults 18 years of age and older. Washington, DC: National Center on Elder Abuse. 2

 Executive Offce of the President, Offce of Management and Budget. (n.d.). OMB Circular A-119: Federal participation in the 

development and use of voluntary consensus standards and in conformity assessment activities. Retrieved from https://www. 

nist.gov/system/fles/revised_circular_a-119_as_of_01-22-2016.pdf 

3

 National Technology Transfer and Advancement Act of 1995, Publ. L. 104-113, including amendment Utilization of consensus 

technical standards by federal agencies, Publ. L. 107-107, section 1115, in 2001. (n.d.). Retrieved from https://www.nist.gov/ 

standardsgov/national-technology-transfer-and-advancement-act-1995 

4

 Guidance on federal conformity assessment activities; National Institutes of Standards and Technology notice of proposed 

rulemaking. 85 Fed. Reg. 7258 (February 7, 2020). Retrieved from https://www.govinfo.gov/content/pkg/FR-2020-02-07/ 

pdf/2020-01714.pdf?utm_campaign=subscription+mailing+list&utm_source=federalregister.gov&utm_medium=email 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 5 

Objectives and Methods 

As part of the Guidelines updates, ACL identifed several key objectives: 

• Determine appropriate updates to the Guidelines. 

• Identify additional topics for inclusion in the Guidelines as needed. 

• Identify topic areas for which research on APS practices is lacking. 

• Determine how frequently ACL should re-engage stakeholders in the process to update the 

Guidelines, and gather ideas on the most effcient way for stakeholders to provide input. 

Similar to the development of the original version of the Guidelines, ACL applied a multistep approach for 

updating the Guidelines, with each step building onto the work from the previous step. These steps include: 

1. an updated literature review to identify new research evidence; 

2. draft revisions and additions to the Guidelines based on new research evidence; 

3. a stakeholder engagement process to obtain feedback for the proposed updates; 

4. a comprehensive data analysis of the feedback received from stakeholders; 

5. a detailed synthesis of the results; and fnally 

6. convening a TEP to refne and build consensus for the updates based on the proposed updates 

and feedback from stakeholders. 

1. Literature Search and Review 

Purpose 

The purpose of the literature search and review was to identify new evidence published in peer-reviewed 

journal articles focused on the evaluation of APS programs and practices. 

Methods 

The literature search applied the same search methods used during development of the original 

Guidelines, but with an updated timeframe and additional databases. The search was conducted using the 

following parameters: 

• Timeframe: April 1, 2014 – November 30, 2018 

• Databases: Applied Social Sciences Index and Abstracts (ASSIA), Dissertations Abstracts, EBSCOhost Academic Search Complete, EBSCOhost MEDLINE Complete, Education Resources Information Center (ERIC), Google Scholar, Lexis-Nexis U.S. Law Reviews and Journals, National Criminal 

Justice Reference Service (NCJRS) Abstracts Database, PILOTS: Published International Literature 

on Traumatic Stress, PubMed, Sage Publications Database, ScienceDirect, Social Services Abstracts, Sociological Abstracts 

• Search terms: abuse, adult protective service, adults with disabilit*, disabled, elder, exploitation, 

fraud, maltreatment, mistreatment, neglect, older adult, outcomes, or vulnerable 

• Inclusion criteria: published in English; contains quantitative data analysis or presents literature 

review; related to or applicable to APS programs, operations, practices, and processes 
6 

The focus for this literature review was on studies reporting on fndings from APS. However, studies 

reporting on effective protective service strategies from the child welfare feld and long-term care 

ombudsman programs were also reviewed if those service strategies may be applicable to the APS feld. 

Selection and categorization of articles for this review was accomplished through the following steps: 

1. Selection: To determine if articles met the purpose and the inclusion criteria for this review, titles 

and narrative descriptions of identifed articles were screened frst. Subsequently, abstracts were 

reviewed to identify relevant articles, and of those deemed relevant after abstract review, full 

articles were reviewed and key information was extracted. 

2. Categorization: Findings from the included articles were reviewed and cross-walked with the 

domains and elements addressed by the Guidelines. Articles were then categorized based on the 

domain and elements they addressed, i.e., which domain(s) and element(s) may be supported, 

updated, or revised based on the article’s fndings. 

Results 

The literature search resulted in 59 journal articles related to or relevant for APS programs and practices. 

After review of the abstracts, 11 articles were excluded because they did not meet the inclusion criteria. All 

remaining articles (N=48) were reviewed in full. Of those, 24 additional articles were excluded because 

they also did not address the purpose of this review. A fnal group of 24 articles met the inclusion criteria 

and were included in the literature review. Three of these articles focused on child protective service 

systems, and the rest focused on APS. 

A full list of references of the 24 articles categorized by the domain and elements the articles address is 

provided in Appendix C. 

Guideline Domains/Elements 5 

The fndings from the 24 included studies were relevant to all but one of the seven Guidelines domains. 

See Figure 1 below for the number of studies by domain. None of the fndings were relevant to domain 

3 (Receiving Reports of Maltreatment). The majority of studies were related to domain 1 (Program 

Administration), and within that domain, most studies (N=5) were related to element 1e (Coordination With 

Other Entities). Seven articles were relevant to domain 5 (Service Planning and Service Implementation); 

of those, fve addressed element 5a (Voluntary Service Implementation). Five articles were relevant to 

domains 4 (Conducting the Investigation) and 6 (Training) respectively. 

5

 As part of the updates to the Guidelines, element 1G, Protecting Program Integrity, was moved up to become element 

1B. The title for element 4C was changed from “Investigations in Congregate Settings” to “Investigations in Residential 

Care Facilities”; the title for element 4D was changed from “Completion of Investigation and Substantiation Decision” to 

“Completion of Investigation and Finding.” The title for domain 5 was changed from “Services Planning and Intervention” to 

“Service Planning and Service Implementation”; element 5A was changed from “Voluntary Intervention” to “Voluntary Service 

Implementation”; and element 5B was changed from “Involuntary Intervention” to “Involuntary Service Implementation.” The 

title for domain 7 was changed from “Evaluation/Program Performance” to “APS Program Performance,” and the content was 

divided into two elements: 7A, Managing Program Data, and 7B, Evaluating Program Performance. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 7 

1. Program Administration 13

2. Time Frames 

3. Receiving Reports of Maltreatment 

4. Conducting the Investigation 

5. Service Planning and Service 7 Implementation 

5 6. Training 

7. APS Program Performance 4

5 

1 

0 2 4 6 8 10 12 14 

Figure 1. Number of Studies by Domain 

Samples Examined in New Literature 

Eighteen of the 24 studies included data from clients served by APS (N=16) or CPS (N=2). For those studies 

focused on APS client data, three focused on clients 65 and older, 10 focused on clients 60 and older, one 

focused on clients 55 and older, one focused on clients 18 and older, and one focused on clients 65+ and 

dependent adults, aged 18–64, who were living in the community. The clients in all but one of these studies 

were identifed by age specifcally, without information regarding the clients’ disability status. Only one 

study specifcally mentioned dependency as a qualifying criterion for the APS program. 

Findings and Implications 

The list below provides an overview of key fndings and implications by Guidelines domain. Note: Articles/ 

fndings may be relevant to more than one domain and therefore may be listed more than once. 

Domain 1. Program Administration 

• More rigorous means of detecting elder abuse are needed to obtain accurate prevalence data and 

to inform policy decisions; clear defnitions and training to standardize the assignment of fndings 

for elder abuse/neglect cases should be established (Mosqueda et al., 2016). 

• Those with the mandated responsibility to report are more likely to report situations that are truly 

mistreatment (i.e., are substantiated through APS investigation) and that will result in victims 

receiving some type of intervention aimed at alleviating their risk (Lees, 2018). 

• The mandatory reporting law for child sexual abuse (CSA) is associated with a substantial and 

sustained increase in identifcation of cases of CSA. A similar law for mandatory reporting of elder 

abuse/neglect may also have a benefcial impact in the identifcation of elder abuse/neglect 

(Mathews, Lee, & Norman, 2016). 
8 

• Results highlight the importance of the forensic interview in child protective services decisions of 

CSA, and the potential role for child advocacy centers in providing trained professionals to conduct 

a high-quality interview during the initial assessment (Brink, Thackeray, Bridge, Letson, & Scribano, 2015). The fndings may also support the use of multidisciplinary teams (MDTs) in APS. 

• Research focused on a forensic MDT model for elder abuse has shown the model to be an effective approach for increasing prosecution rates and conservatorship for cognitively impaired older 

adults and for reducing the rate at which cases re-entered the APS system (Wilber, Navarro, & 

Gassoumis, 2014). 

• The Forensic Center model offers an effective pathway in bringing cases to the attention of a public 

guardian for investigation and conservatorship, thereby increasing conservatorship as a remedy 

for those who require the highest level of protection (Gassoumis, Navarro, & Wilber, 2015). 

• MDT models are effective for intervening with victims of elder mistreatment. In particular, fndings provide support for an integrated social work–legal interdisciplinary mode (Rizzo, Burnes, & 

Chalfy, 2015). 

• Clients are often willing to accept an offer of additional mental health services at the same time that 

they are receiving mistreatment resolution service. Additionally, results support the potential for 

elder abuse service providers to work in tandem with mental health clinicians (Sirey et al, 2015). 

• Results provide evidence to support efforts to improve collaboration between child welfare and 

drug and alcohol services providers (He & Philips, 2017). (These results may also suggest a potential beneft for collaboration between APS and substance use treatment providers since recent 

referrals of older adults to APS show an increase in substance abuse among clients [see Susman, 

Lees, & Fulmer, 2015]). 

• Using a Web-based portal and low-cost videophone technology to connect an APS agency and its 

clients to a centralized geriatric and elder mistreatment expert medical team for virtual in-home 

assessments could serve as a model for fostering collaboration between state protective agencies 

and medical professionals (Burnett, Dyer, Clark, & Halphen, 2018). 

• Findings highlight the importance of creating a positive and supportive work environment for APS 

workers, and of implementing management strategies for the prevention of burnout among APS 

workers (Ghesquiere, Plichta, McAfee, & Rogers, 2018). 

• Education is needed across agencies and the general population regarding emotional abuse, its 

negative effects, and methods of reporting to police and other authorities (Acierno, 2018). 

• Educational interventions for professionals and families may help to enhance and support APS 

communication with other members of the health care team and potentially reduce repeated 

involvement with the APS system (Susman, Lees, & Fulmer, 2015). 

Domain 2. Time Frames 

• A longer-term, relationship-based intervention for entrenched elders who are reluctant to 

receive services may be effective and therefore worth considering (Mariam, McClure, Robinson, 

& Yan, 2015). 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 9 

Domain 4. Conducting the Investigation 

• The Elder Abuse Decision Support System short form can be used to standardize and increase effciency of APS investigations, and it may also offer researchers new options for brief elder abuse 

assessments (Beach et al., 2017). 

• Results highlight the importance of the forensic interview in child protective services decisions 

of CSA and the potential role for child advocacy centers in providing trained professionals to 

conduct a high-quality interview during the initial assessment (Brink, Thackeray, Bridge, Letson, 

& Scribano, 2015). The fndings may also support the use of MDTs in APS. 

• A list of standardized questions for caseworkers to use during investigation may provide an 

objective and detailed approach for investigation (Conrad, Iris, & Liu, 2017). 

• The elder abuse forensic center MDT model is an effective approach for conducting investigations 

(Wilber, Navarro, & Gassoumis, 2014). 

• Using a Web-based portal and low-cost videophone technology to connect an APS agency and its 

clients to a centralized geriatric and elder mistreatment expert medical team for virtual in-home 

assessments could serve as a model for fostering collaboration between state protective agencies 

and medical professionals (Burnett, Dyer, Clark, & Halphen, 2018). 

Domain 5. Service Planning and Service Implementation 

• Elder mistreatment social service programs should aim to promote elder participation in supportive community social outlets, e.g., senior centers (Burnes, Rizzo, & Courtney, 2014). When social 

support from family or friends is unavailable or defcient, policy should direct services to compensate or supplement this factor (Acierno, Hernandez-Tejada, Anetzberger, Loew, & Muzzy, 2017). 

• Findings highlight the need to identify and intervene in elder mistreatment cases as early as possible in the mistreatment trajectory and the need to develop targeted safety planning for clients 

experiencing different forms of abuse and/or neglect (Burnes, Rizzo, & Courtney, 2014). 

• Findings underscore the importance of differentiating among the various types of maltreatment as different profles indicate the need for interventions tailored to meet the unique characteristics associated 

with each type of abuse, which may lead to greater victim safety (Jackson & Hafemeister, 2014). 

• Clients are often willing to accept an offer of additional mental health services at the same time that 

they are receiving mistreatment resolution service. Additionally, results support the potential for 

elder abuse service providers to work in tandem with mental health clinicians (Sirey et al, 2015). 

• A longer-term, relationship-based intervention for entrenched elders who are reluctant to receive 

services may be effective and therefore worth considering (Mariam, McClure, Robinson, & Yan, 2015). 

• The Forensic Center model offers an effective pathway in bringing cases to the attention of a public 

guardian for investigation and conservatorship, thereby increasing conservatorship as a remedy 

for those who require the highest level of protection (Gassoumis, Navarro, & Wilber, 2015). 

• Findings suggest that goal attainment scaling is a feasible measurement strategy to implement in 

the APS context (Burnes, Connolly, Hamilton, & Lachs, 2018). 
10 

Domain 6. Training 

• The Elder Abuse Nurse Examiner Curriculum is effective in improving sexual assault nurse examiners’ self-reported knowledge of and perceived competence in delivering elder abuse care (DuMont, 

Kosa, Yang, Solomon, & Macdonald, 2017). 

• More rigorous means of detecting elder abuse are needed to obtain accurate prevalence data and 

to inform policy decisions; clear defnitions and training to standardize the assignment of fndings 

for elder abuse/neglect cases should be established (Mosequeda et al., 2016). 

• Interdisciplinary training programs may be an effective way to learn and produce changes in 

knowledge and clinical practice (Pickering, Ridenour, Salaysay, Reyes-Gastelum, & Pierce, 2018). 

• Multimethod training programs for improving confdence, knowledge, and case management skills 

– including how to identify, report and investigate cases of suspected abuse – are effective and 

could be made available online to all health authorities for implementation as appropriate to local 

operational needs (Storey & Prashad, 2018). 

• Findings highlight the importance of creating a positive and supportive work environment for APS 

workers, and of implementing management strategies for the prevention of burnout among APS 

workers (Ghesquiere, Plichta, McAfee, & Rogers, 2018). 

Domain 7. APS Program Performance 

• APS may beneft from examining its service areas and determining which specifc areas may require expansion to meet client needs (Booker, Breaux, Abada, Xia, & Burnett, 2018). 

• Findings highlight the need to identify and intervene on elder mistreatment cases as early as possible in the mistreatment trajectory and the need to develop targeted safety planning for clients 

experiencing different forms of abuse and/or neglect (Burnes, Rizzo, & Courtney, 2014). 

• Findings suggest that goal attainment scaling is a feasible measurement strategy to implement in 

the APS context (Burnes, Connolly, Hamilton, & Lachs, 2018). 

• Educational interventions for professionals and families may help to enhance and support APS 

communication with other members of the health care team and potentially reduce repeated 

involvement with the APS system (Susman, Lees, & Fulmer, 2015). 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 11 

2. Development of Proposed Updates 

The fndings from the literature review were then used to inform draft updates and revisions to the 2016 

Guidelines domains and elements. Specifcally, fndings from recently published studies were used to 

support the guidance statements and/or inform revisions or updates to the background and guidance 

statements in the elements. As noted, the fndings had implications for all but one of the Guidelines 

domains. For the six relevant domains, the articles’ fndings were used to make revisions by either adding 

text to the background but not changing the guidance statements or adding text to the background 

and changing the guidance statements. There were no cases where current guidance was deleted. It is 

important to note that several studies had fndings that impacted several domains. 

3. Stakeholder Engagement 

The 2016 Guidelines were developed with extensive input from stakeholders representing multiple 

professional felds, including staff from APS, aging, long-term care, disability, domestic violence, sexual 

assault, and victim services networks; legal services and law enforcement; native and tribal communities; 

and federal staff. Members of the public also provided feedback. The goals of the stakeholder engagement 

and outreach process were to hear from all stakeholders about their experiences with APS, ensure all 

stakeholders understand why and how ACL is leading the development of Guidelines for APS, and provide 

interested parties an opportunity to give input into the process and content of the Guidelines. Throughout 

the process, ACL’s stakeholder engagement and outreach endeavored to 

• respect people’s history and experience with APS, and their other life experiences; 

• empower the public and stakeholders to contribute to the development of national APS guidelines 

in a meaningful way; 

• understand the public’s vision for APS and for ACL’s role in APS; 

• build consensus on proposed guidelines by including representatives from materially affected and 

interested parties, to the extent possible; and 

• incorporate a civil rights/personal rights perspective in developing the system guidelines. 

For the updates, the public as well as professionals who may report and/or respond to abuse, neglect, 

and fnancial exploitation experienced by older adults and adults with disabilities were invited to provide 

feedback for the draft updates to the Guidelines via two main methods, a public comment period and 

stakeholder webinars. 

Public Comment Period 

Stakeholders were invited to provide feedback for the proposed updates to the Guidelines via the ACL’s 

request for information (RFI) Web page, hosted at https://acl.gov/about-acl/public-input, and direct 

e-mail. The Web page was publicly available and included information about the project and key materials 

(i.e., the Guidelines, suggested revisions and/or additions, literature references). Stakeholders had the 

opportunity to provide feedback via the ACL RFI Web page from the end of March until the end of May 2019. 
12 

Stakeholder Webinars 

Stakeholders were also invited to provide feedback via webinars. Five webinars were held during April 

and May 2019. For a recording of one of the webinars, use this link: http://bit.ly/APSwebinarApril29.

6 

The webinar platform allowed for the presentation of visual content (draft revision), polling, and written 

comments by participants. As part of the webinar registration, stakeholders were asked to indicate the state 

and feld they represented. During the webinar, participants were encouraged to respond (voluntarily) to the 

following polling questions: 

1. What professional group are you representing today?7 

2. Before preparing for today’s call, how familiar were you with the current National APS Guidelines?8 

3. How frequently should the Guidelines be updated in the future?9 

The following sections provide a summary of the analyses conducted for the stakeholder feedback, as well 

as the results from the analysis, limitations, and implications. 

4. Analyses of Stakeholder Feedback 

Quantitative Analysis 

Quantitative data collected as part of the webinar registration and webinar polls (state, professional feld 

represented, etc.) were imported to an Excel fle. The data were analyzed using functions within Excel, 

including counts and percentages. 

Qualitative Analysis 

Public comments from the ACL RFI webpage and e-mails were saved to a Word fle and identifying 

information (i.e., e-mail address and names) was removed. Stakeholder webinars were recorded and 

transcribed. Written comments provided during the webinar were saved, exported, and added to the 

webinar transcript Word fles. The fnal transcript fles were then cleaned and prepared for analysis. 

The fles were imported into ATLAS.ti software, a dedicated qualitative analysis tool, to allow for desired 

information to be extracted from the collected data and analyzed for trends and predominant themes. If 

known, comments were frst tagged with an identifer to indicate the feld the commenters represented 

(e.g., APS network, disability network, federal agency). Subsequently, multiple steps were applied for the 

analysis of all comments using multiple researchers: 

1. First, comments relevant to the feedback for the Guidelines were selected/highlighted. The 

selected comments were then used for subsequent coding. 

2. Where applicable, comments were coded to indicate to which Guideline domain(s) and element(s) 

they were related. 

6

 No credentials are required to access the webinar. If prompted for credentials after opening the link, click on “Cancel,” and 

the recorded webinar should proceed to play on the Adobe Connect platform. 

7

 Response options: APS Network; Aging Network; Minority Aging Network; Disability Rights Network; Domestic Violence, 

Sexual Assault, and Victim Service Network; Federal Agency; General Public; Law Enforcement; Legal Services Network; LongTerm Care Network; Tribal Community; Other. 

8

 Response options: extremely familiar; very familiar; somewhat familiar; slightly familiar; not at all familiar 

9

 Response options: every year; every 2 years; every 3 years; every 4 years; every 5 years 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 13 

 

3. To establish interrater reliability, three researchers frst randomly selected a subset of comments and 

coded them independently, then reviewed the coding jointly until agreement was reached. Using this 

process, the researchers created an analysis code book consisting of the consensus codes. 

4. Two researchers then used grounded theory and constant comparative methods to code all 

comments and develop emerging and subthemes from the various codes. The researchers 

discussed comments and added new codes as needed. New codes identifed as part of this 

process were added to the code book. 

5. Codes were then analyzed using the Atlas.ti Code-Document Table tool. The tool allowed the researchers 

to identify the number of comments by specifc code, as well as by group of codes (code families). 

5. Stakeholder Feedback Analyses: Results 

The following section provides results from the quantitative and qualitative data analyses using data 

from the participation on the webinars as well as all comments received via the webinars and public 

comment period. 

Quantitative Results 

Data Related to Webinar Participants 

Quantitative results pertain to data collected as part of the fve webinars, including number of participants, 

states and professional felds represented by participants, familiarity with the Guidelines, and frequency 

with which the Guidelines should be updated in the future. 

Across the fve webinars, approximately 190 stakeholders 10 participated, representing 39 states and the 

District of Columbia. California had the the highest level of participation (14%), following by Maryland 

(6%), Colorado (5%), Illinois (5%), Missouri (5%), New York (5%), North Carolina (5%), Tennessee (5%), 

and Texas (5%). 

Participants represented 10 felds, with the majority of participants representing the APS network, followed 

by those representing other felds (e.g., research, academia) and those representing the aging network 

(see Table 1). 

10 The actual number may have been higher since participants who only called in to the conference line and did not use the 

webinar link, and who did not provide written or verbal comments, could not captured in the count. 
14 

Table 1. Fields Represented by Webinar Participants 

Field Percentage 

APS Network 66% 

Other (e.g., research, academia) 13% 

Aging Network 11% 

Long-Term Care Network 3% 

Federal Agency 2% 

Disability Rights Network 1% 

Domestic Violence, Sexual Assault, and Victim Service Network 1% 

General Public 1% 

Law Enforcement 1% 

Legal Services Network 1% 

When participants were asked during the webinar how familiar they were with the Guidelines prior 

to the webinar, a little over one third indicated being extremely or very familiar with the Guidelines. 

Approximately half of participants indicated being somewhat or slightly familiar with the Guidelines 

(see Table 2). 

Table 2. Familiarity With Guidelines Prior to Webinar 

Familiarity Percentage 

Extremely familiar 3% 

Very familiar 32% 

Somewhat familiar 30% 

Slightly familiar 24% 

Not at all familiar 10% 

When asked during the webinar how often the Guidelines should be updated in the future, most 

participants recommended the Guidelines be updated every 2 or 3 years (see Table 3). None of the 

participants recommended the Guidelines be updated every year. 

Table 3. Frequency for Updating the Guidelines 

Frequency Percentage 

Every 2 years 40% 

Every 3 years 42% 

Every 4 years 16% 

Every 5 years 2% 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 15 

278 

216 

Number of comments 

related speciÿcally to 

the Guidelines content Number of 

relevant comments 

Data Related to Public Comments 

For all comments received via the webinars and the public comment period, at total of 278 comments were 

coded as containing relevant feedback. Of those, 216 comments were related specifcally to the content 

of the Guidelines (e.g., background and guidance). The feedback was related to supporting proposed 

updates or expressing concerns about proposed updates, challenges for implementing the Guidelines, 

recommendations for additional revisions for specifc domains/elements, and global feedback regarding 

Guidelines (e.g., use of victim vs. client). Other comments (N=62) were coded as being related to feedback 

about aspects outside the content of the Guidelines (see Figure 2a). These included the format of the 

Guidelines, the frequency and process for updating the Guidelines, the dissemination of the Guidelines, 

and research gaps. 

Figure 2a. Number of Comments Coded for Containing Relevant Feedback 

Relevant comments were provided by stakeholders representing multiple professional felds, including 

those shown in Figure 2b, below. As expected, professionals representing the APS network provided the 

majority of comments (69.1%), followed by professionals representing the long-term care network (10.4%), 

consultants/contractors (6.5%), and the aging network (5.2%). Comments made by stakeholders from 

the following felds were grouped into “other,” given the low number of comments: domestic violence and 

sexual assault network, federal agencies, state agencies, legal services network, disability rights network, 

and the general public. Together, these stakeholders provided 5.2% of the relevant comments. The data 

are based only on stakeholders who chose to identify their feld. Stakeholders were encouraged to identify 

themselves, but were permitted to provide comments anonymously. 
16 

Domain 7. APS Program 

Performance 4.0% 

Domain 6. Training 17.5% Domain 1. Program 

Administration 28.2% 

Domain 2. Time Frames 13.4% 

Domain 5. Service Planning and

Service Implementation 24.8% 

Domain 4. Conducting Domain 3. Receiving Reports 

the Investigation 11.4% of Maltreatment 0.7% 

 

 

Aging Network 5.2% 

Academia/Research 3.5% 

Other 5.2% 

Long-Term Care Network 10.4% 

Consultant/Contactor 6.5% 

APS Network 69.1% 

Figure 2b. Percent of All Relevant Comments From Stakeholders by Field 

Stakeholders commented on the proposed updates as well as the original content. Stakeholders provided 

comments for all seven domains, including domain 3, for which no updates were proposed. As shown in 

Figure 3 below, the majority of comments focused on Domain 1, Program Administration (28.2 %), followed 

by Domain 5, Service Planning and Intervention (24.8%), and Domain 6, Training (17.5%). One stakeholder 

provided a comment for Domain 3, Receiving Reports of Maltreatment. Because of the low number of 

comments by representatives of felds outside of the APS Network, analysis of quotations by individual 

stakeholder group is not recommended and was not conducted. 

Figure 3. Percent of Relevant Comments by Guidelines Domains 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 17 

Table 4 shows the number of relevant comments for each element, listed from highest to lowest. Element 

6B, Caseworker Initial and Ongoing Training, had the most relevant comments (N=22), followed by elements 

2C, Closing the Case (related to time frames; N=17); 5A, Voluntary Service Implementation (N=17); 1F, 

Coordination With Other Entities (N=14); 5C, Closing the Case (related to service planning and service 

implementation; N=13); and 4A, Determining If Maltreatment Has Occurred (N=10). 

Table 4. Number of Relevant Comments by Guidelines Elements 

Element 

Number of 

Relevant Comments 

6B. Case Worker Initial and Ongoing Training 22 

2C. Closing the Case (related to time frames) 17 

5A. Voluntary Service Implementation 17 

1F. Coordination With Other Entities 14 

5C. Closing the Case (related to service planning and service implementation) 13 

4A. Determining If Maltreatment Has Occurred 10 

1E. Mandatory Reporters 9 

5B. Involuntary Service Implementation 7 

6C. Supervisor Initial and Ongoing Training 5 

1G. Program Authority, Cooperation, Confdentiality, and Immunity 4 

4B. Conducting an APS Client Assessment 4 

1I. Access to Expert Resources 3 

1A. Ethical Foundation of APS Practice 2 

1B. Protecting Program Integrity 2 

1D. Population Served 2 

1K. Worker Safety and Well-Being 2 

1L. Responding During Community Emergencies 2 

2B. Completing the Investigation 2 

4C. Investigations in Residential Care Facilities 2 

1C. Defnitions of Maltreatment 1 

1H. Staffng Resources 1 

1M. Community Outreach and Engagement 1 

2A. Responding to the Report/Initiating the Investigation 1 

3B. Screening, Prioritizing, and Assignment of Screened-in Reports 1 

6A. Caseworker and Supervisor Minimum Educational Requirements 1 

As noted, several (N=216) of the comments involved specifc feedback regarding the proposed updates to 

the Guidelines. Specifcally, stakeholders voiced support or agreement for the updates (12% of comments), 

expressed concerns or disagreement (3.2% of comments), noted challenges for their implementation (7.4% 

of comments), noted global comments (22.2% of comments), and provided specifc recommendations for 

additional revisions (55.1% of comments). Recommendations were related to revising specifc wording, 

adding additional content/wording, providing clarifcation, etc. See Figure 4 for the number of comments 

by type of recommendation. Feedback regarding specifc recommendations is summarized in the next 

section (Qualitative Results). 
18 

Revise wording 

Remove Content 

Referencing other sources/programs 

New section 

New practice to consider 

Deÿnition 

Clariÿcation 

Additional content 51 

10 20 30 40 50 60 

40 

3 

7 

7 

8 

1 

2 

0 

Figure 4. Number of Comments Related to Specifc Recommendations for Revisions 

Qualitative Results 

This section provides a summary of comments received during the stakeholder webinars and the public 

comment period. Stakeholders were invited to comment on the proposed updates, as well as other 

content, and suggest additional topics for inclusion in the Guidelines. In addition, stakeholders were 

invited to provide feedback regarding research gaps and processes for updating the Guidelines in the 

future. The summary that follows presents a synthesis of all comments (themes) organized by topic, with 

sample verbatim quotations, in the shaded boxes, for further illustration. Except for words in brackets 

added for clarifcation, these comments are unedited, copied exactly as stated in stakeholders’ feedback. 

Topics include global comments regarding the Guidelines content, comments specifc to the Guidelines 

domains and elements, and comments related to research gaps and processes for updating the Guidelines. 

A detailed list of all verbatim quotations related specifcally to the Guidelines domains and elements, and 

coding applied, is provided in Appendix D. 

Global Comments 

Inclusiveness of Guidelines Topics 

Stakeholders noted that the Guidelines are comprehensive and address all key areas (domains) that are 

relevant for processes related to APS investigations. 

I just wanted to say I was looking over the areas that you kind of put everything into as far 

as investigation, and I was wracking my brain to think if anything didn’t ft into it and I think 

you have them all covered. That is my only comment. You have all the areas that cover APS 

mapped out well. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 19 

Beneft of the Guidelines/Impact 

Stakeholders noted that the Guidelines serve as a great tool to help them advocate for additional 

funding and staff. Given that resources for the APS feld are limited at this time, the Guidelines may be 

considered “aspirational,” identifying best practices that should be implemented given suffcient funding. 

Stakeholders agreed that the Guidelines should maintain this aspirational approach, even though 

programs may not be able to implement all practices in reality. Rather, the Guidelines help set the standard 

and support future planning and legislative advocacy. Stakeholders also noted that it is important to 

consider the implications of the document and to communicate to leaders in the feld that these practices 

can only be implemented or attained with suffcient resources and support. 

I think the problem with [the recommendations], it is aspirational and I think we all 

would agree we would like to do that. But when these guidelines are produced, executive 

leadership in a lot of organizations take that as a best practice and don’t realize that is 

aspirational and we will get there some days. So, I think we need to balance that.” 

I think all of those are again aspirational, and worth putting in there for us to advocate for 

funding to be able to do all of that. We all know prevention is better than intervention later. I 

mean... all of us these make sense to me. 

Barriers/Challenges for Implementation 

Stakeholders highlighted that the Guidelines can be hard to operationalize with the current independent 

case management system that does not receive state or federal support. In addition, specifc 

recommendations, such as keeping cases open and the use of MDTs, are challenging to implement without 

a better funding system, such as that in child welfare. 

Populations 

Stakeholders recommended that the Guidelines provide more clarity on the populations that are being 

addressed. Specifcally, it should be made clear, and language should refect, that the Guidelines address 

all adult populations, including younger adults with disabilities, and not just elders/older adults. 

Stakeholders also recommended that the Guidelines specifcally highlight persons living with dementia as 

one of the at-risk populations. 

We were grateful for the opportunity to comment on the 2016 National Voluntary Consensus 

Guidelines for State APS Systems during their development. At that time, we offered a 

variety of suggestions as to how APS systems can identify and work with persons living with 

dementia. However, ACL declined to incorporate these suggestions or specifcally identify 

this particularly vulnerable population. While we understand the need for these guidelines 

to remain broadly applicable, every state across the country is expected to experience 

an increase of at least 12 percent in the number of people with Alzheimer’s between 2019 

and 2050 and working with these individuals can be fundamentally different from working 

with other APS clients. For example, persons living with dementia often have diffculty 

understanding or explaining situations and their behaviors may be viewed by APS personnel 

as uncooperative, disruptive, or combative. Therefore, we encourage ACL to identify this 

population specifcally throughout the updated guidelines. 
20 

Global Changes 

Stakeholders recommended revising some of the wording throughout the Guidelines. One of the 

recommendations focused on including wording that emphasizes the “aspirational” nature of the 

Guidelines and refects that these are best practices that are contingent on funding and resources. 

Suggested wording that could be used where appropriate included “as much as possible” or “if 

resources allow” or “as funding permits”; “funding permitting”; and “when available or where available.” 

Stakeholders noted that such wording would help ensure that workers are not put in a position of having 

to provide certain services when they do not have the resources, but that programs that have the resources 

are encouraged to adhere to the guidance. 

Stakeholders also noted that the word “maltreatment” is used consistently to talk about both abuse 

and self-neglect. However, maltreatment more accurately describes abuses, and the language in the 

Guidelines should be more nuanced, using abuse and/or self-neglect depending on the context. Additional 

recommendations included the use of the word “client” rather than “elder,” to be inclusive of individuals 

who are younger, and to add or revise language as needed to highlight clients’ autonomy. 

Should there be some language: try to preserve as much of the client’s autonomy 

as possible? 

Client vs. Victim 

Overall, stakeholders favored the use of the term “client” rather than “victim” because it is more positive 

and empowering of individuals and more strength based. Additionally, because the word “victim” implies 

a perpetrator some, people do not think it includes those who self-neglect. “Client” is also consistent with 

language used in NAMRS. 

Other potential recommended terms that could be used instead of “victim” include “person who experienced 

maltreatment” or “person alleged to have experienced maltreatment.” Stakeholders noted that they use 

“alleged victim” until it is determined that abuse has occurred, when the term changes to “client.” 

Other stakeholders noted that the specifc term may not matter so much as long as it is defned so readers 

know that, whether “client “or “victim” is used, it refers to the same individual. 

Domain 1. Program Administration 

1A. Ethical Foundation of APS Practice/1G. Program Authority, Cooperation, Confdentiality, and Immunity 

No updates were proposed to this section, but stakeholders provided recommendations for the content in 

the original Guidelines for this section. Stakeholders recommended that language be added to recommend 

that the code of ethics and policies be reviewed annually. They also highlighted that the Guidelines should 

encourage APS to place greater emphasis on putting the client frst. Specifcally, it was recommended that 

language be added to emphasize that APS needs to comply with the Americans with Disabilities Act; that 

APS represents the patient and not the facility (e.g., assisted living facility); that a separate entity should 

investigate abuse by facilities; and that competency tests should be conducted by licensed professionals. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 21 

APS represents nursing homes/assisted living facilities. APS petitions for guardianships 

at the direction of assisted living facilities. APS refuses to comply with the American for 

Disabilities Act when it comes to seniors with hearing issues and vision issues. In our 

situation APS refused to investigate the medically unnecessary use of morphine by a facility. 

If APS at the request of a facility can restrict family members from medical records, care and 

transitioning out of a facility, then APS is representing the facility. We do not understand 

why an agency that is supposed to protect our seniors is instead representing a private 

industry and support staff: i.e., nursing homes/guardians and support staff. We also do 

not understand why seniors are NOT protected by the Americans with disability act. Thus, 

respectfully we suggest as guidelines that APS be required to comply with American with 

Disabilities Act, that APS no longer be the agency that nursing homes call for assistance, 

that APS represent the patient not the facility, and that a separate unit be set up to deal 

with drug abuse by facilities. We would also like to see competency tests done by licensed 

professionals. Above all APS should put the patient frst. 

1B. Protecting Program Integrity 

No updates were proposed to this section. However, stakeholders provided recommendations for the 

content in the original Guidelines for this section. Stakeholders recommended that content be added to the 

Guidelines to encourage APS programs to develop a confict of interest form and policies and procedures 

that provide remedies for conficts whenever possible. In addition, stakeholders provided specifc 

suggestions for changes in the text and proposed adding a new paragraph on the “right of person alleged 

responsible for maltreatment.” (See suggested revisions below.) 

1. Add underlined text: “It is recommended that APS systems create and implement 

policies to ensure that the APS program is held to high standards or integrity. APS 

program policy and standards should be transparent and available to the public. Policies 

are needed to address the issues below:” 

2. Suggest the following revisions to the paragraph on client rights: “Client rights: 

At the time of the initial interview with that person, APS programs should provide 

an explanation of APS program and goals, and the client’s rights, in terms that are 

reasonably understandable to the adult who is the subject of the investigation who may 

have experienced maltreatment.” 

3. Suggest adding the following paragraph: “Rights of person alleged responsible for 

maltreatment: At the time of the initial interview with that person, APS programs should 

provide an explanation of APS program and goals, and the rights of the person, in terms 

that are reasonably understandable to the adult who is the subject of the investigation.” 

1C. Defnitions of Maltreatment 

Stakeholders recommended that the section on defnitions of maltreatment in the Guidelines also include 

language to encourage APS to establish defnitions for case fnding categories (e.g., confrmed, unfounded, 

inconclusive) and to provide training on the application of those defnitions. 
22 

We recommend that the guideline be revised as follows [add underlined sentence]: “It 

is recommended that APS systems defne and respond to, at a minimum, reports of the 

following categories of maltreatment: physical, emotional, and sexual abuse; fnancial 

exploitation; neglect; and self-neglect. APS system should establish clear defnitions for the 

terms “confrmed,” inconclusive,” and “unfounded,” and provide training to its employees on 

these defnitions, as well as how cases should be assigned to the different categories. 

1D. Population Served 

No updates were proposed to this section, but stakeholders offered recommendations for the content 

in the original Guidelines for this section. Stakeholders recommended that the section on population 

served be expanded to include individuals who are victims of transnational scams and that the Guidelines 

specifcally identify and address how APS systems can identify and work with persons living with dementia. 

APS nationally could provide guidance on working with these victims [victims of transnational 

scams] in safety planning to mitigate against further losses or contact with the scammers. In 

addition, several states currently don’t include these victims in the types of cases that state 

or local APS may investigate or assist. Their state regulations either do not allow for assisting 

in fnancial exploitation that is not by someone locally (or a trusted position) or they are 

not seen as in ‘imminent danger’. Yet, we know that undue infuence, and age associated 

fnancial vulnerability, mild cognitive impairment and the various dementia’s, as well as 

depression and loneliness can make older adults more susceptible, and cause them to lose 

their life savings. 

1E. Mandatory Reporters 

Stakeholders recommended several revisions to the list of mandatory reporters, including removing 

“f, Victim service providers,” and “g, Long-term care providers, including home health providers”; and 

to change the wording for item j [new text is underlined] “j, Anyone engaged in the care of or providing 

services to a vulnerable adult.” Stakeholders suggested adding the terms “civil and criminal” for the 

content related to immunity protections. 

Stakeholders expressed being supportive of exemptions to the mandatory reporting requirements if they 

are informed by professional licensing standards, as well as state and federal laws that would exempt 

certain categories of professionals from mandatory reporting. For example, stakeholders recommend 

specifc reference to the Long-term Care Ombudsman (LTCO) program. 

Under the section heading of “Guideline”, we recommend that a reference to the 

Ombudsman Program is added to the second sentence such as [this underlined addition]: 

“Exemptions to mandatory reporting requirements, such as the exemption of representatives 

of the Offce of the State Long-Term Care Ombudsman, should be consistent with...”. Given 

our closely-linked services with APS, and because the Ombudsman Program is a program of 

the Older Americans Act and overseen by ACL, it is important to specify that representatives 

of the Offce are not mandatory reporters. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 23 

1F. Coordination With Other Entities 

Overall, stakeholders agreed with the proposed changes for element 1E, noting that the changes are 

consistent with the literature. Several stakeholders noted, though, that other groups may need to be added 

to the list of organizations/agencies with which APS should collaborate, including the LTCO program; the 

attorney general; protection and advocacy organizations; licensing and certifcation organizations; local 

and state area agencies on aging or departments of aging; department of disabilities; and entities that 

investigate transnational scams (e.g., law enforcement). Stakeholders also emphasized the collaboration 

with crisis intervention teams as part of law enforcement. 

Is there anything being done to ‘improve APS response nationally in assisting each state’s 

APS in regards to assisting older and other vulnerable adult victims (and their families) of 

transnational scams. This would include the importance of mandating that APS additionally 

fle an IC3.gov and FTC.gov report in addition to cross reporting to local law enforcement, 

especially where the victim (or family member) is unable or unwilling. 

For formal collaboration with state LTCO (SLTCO) programs, including memoranda of understanding and 

colocation, stakeholders noted that the Guidelines should refect important caveats. Specifcally, the 

Guidelines should highlight that colocating APS and LTCO staff may present a confict of interest. Other 

stakeholders raised the question whether this section may be an appropriate place for defning the 

different types of MDTs. 

While the SLTCO is in favor of collaboration to produce best outcomes, it is important to note 

that the suggestion to co-locate APS and SLTCO staff is currently an organizational confict 

of interest under Section 712 of the Older Americans Act. It is evident in the original text 

of the OAA and its subsequent reauthorizations that Congress contemplated residents of 

long-term care facilities would be best served by ombudsmen who are focused, independent 

advocates; therefore, Congress included language to prohibit conficts of interest at both the 

individual and organizational level. Section 712(f )(2)(A)(vi) of the Older Americans Act speaks 

specifcally to this issue, and identifes co-location of the SLTCOP with an organization that 

provides adult protective services as an organizational confict of interest. The regulations 

promulgated by DHHS to administer the OAA codify that co-locating the SLTCOP and APS is 

an organizational confict of interest. 

1G. Program Authority, Cooperation, Confdentiality, and Immunity 

No updates were proposed to this section, but stakeholders provided recommendations for the content in 

the original Guidelines for this section. Stakeholders recommended that two additional groups be added to 

the groups/teams for which APS should be given the authority to cooperate and share information related 

to an APS case: “informal support persons and licensed providers” and “non-APS members including 

ombudsman program and licensing and certifcation organization.” Stakeholders also recommended 

additional text to provide more clarity on “access to victims.” (See suggested text below.) 
24 

This guideline does not provide guidance when it is the vulnerable or older adult who is 

refusing access. Suggest [adding underlined text]: “It is recommended that APS systems 

be given the authority to access alleged victims of maltreatment and the authority to 

prevent another’s interference in an APS case, including access of the older or vulnerable 

adult. That access includes the authority to conduct a private, face-to-face interview with 

the alleged victim. 

1H. Staffng Resources 

No updates were proposed to this section, but stakeholders provided recommendations for the content in 

the original Guidelines for this section. Stakeholders provided specifc suggestions for changes in the text. 

(See suggested revisions below.) 

1. Add the word “periodic” to this sentence: “To reach that goal, it is recommended 

that APS systems conduct periodic caseload studies to determine and implement 

manageable ratios.” 

2. Add the word “suggested” to this sentence: “Finally, it is recommended that there be a 

suggested limit on the number of workers supervised by each supervisor.” 

3. Add the words “or guardianship” to this sentence: “differences in complexity of 

allegations (e.g., many fnancial exploitation cases and self-neglect or guardianship 

cases take signifcant time and expertise). 

1I. Access to Expert Resources 

Overall, stakeholders agreed with the proposed changes for element 1I, noting that the changes are 

appropriate and needed. For the original guidance for APS to dedicate resources and develop systems and 

protocols to allow for expert consultation, stakeholders recommended adding the following professions: 

“elder law, substance use, fnancial exploitation, and long-term care.” 

I fnd the update appropriate and needed. 

1K. Worker Safety and Well-Being 

Stakeholders noted that they appreciated the added content on worker safety in the background section 

and also recommended specifc suggestions for changes in the Guideline section. (See suggested 

revisions below.) 

1. Add the words “and training” to this sentence: “It is recommended that APS systems 

create policies and protocols, and provide adequate resources and training related to 

worker safety.” 

2. Add the words “or client” to item number 7: “Workers should never be required to 

respond to a situation that would put the worker or client at risk without adequate safety 

supports available.” 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 25 

 

1L. Responding During Community Emergencies 

No updates were proposed to this section, but stakeholders provided recommendations for the content 

in the original Guidelines for this section. Stakeholders recommended that guidance be added on the 

development of a national working group to develop policies, protocols, and trainings on APS emergency 

preparedness and response. Stakeholders also recommended that guidance be added for establishing a 

process for the role of APS in emergency relocations of facility residents (assisted living, nursing home, 

and other settings). 

[Recommend adding guidance regarding the] development of a national working group to 

develop policies, protocols and trainings on APS Emergency Preparedness and Response. Add 

training and related resources to Core Competency Training for APS Workers and Supervisors. 

1M. Community Outreach and Engagement 

Stakeholders recommended adding content to note that programs should consider using research on 

public perceptions of aging, ageism, and elder abuse and how to use communication tools, such as those 

developed by the Frameworks Institute and other aging organizations for the Reframing Elder Abuse Project. 

Consider utilizing research on public perceptions of aging, ageism, and elder abuse and 

how to use communication tools developed by Frameworks Institute, NCEA and eight other 

national aging organizations for the Reframing Elder Abuse Project. 

Domain 2. Time Frames 

2A. Responding to the Report/Initiating the Investigation. 

No updates were proposed to this section, but stakeholders provided a recommendation for the content 

in the original Guidelines for this section. Stakeholders recommended reconsidering using the term 

“investigation” as it may not be an appropriate term for this feld and other terms, such as “assessment for 

neglect” and/or “fact-fnding assessment for abuse and exploitation,” may be more appropriate. 

Investigation is inconsistent with a social service program when the older or vulnerable 

adult is the subject or when a primary support person in relationship with the older 

or vulnerable adult is the subject. Suggest assessment for neglect and/or fact-fnding 

assessment for abuse and exploitation. Change to “2A. Responding to the report/initiating 

the Fact Finding/Assessment.” 

2B. Completing the Investigation 

No updates were proposed to this section, but stakeholders provided recommendations for the content 

in the original Guidelines for this section. Consistent with the recommended revision for element 2A, 

stakeholders also recommend reconsidering replacing the term “investigation” in the element title for 

2B. In addition, stakeholders suggested specifc changes for the last bullet in the Guideline section. (See 

suggested revisions below. 
26 

Add the words “with supervisory approval” to this guideline: “allow for extensions for good 

cause with supervisory approval.” 

2C. Closing the Case 

For the listed case close criteria, stakeholders recommended adding “the client had died” to the list. 

Overall, stakeholders were supportive of the proposed updates for longer-term case monitoring for elders 

who are reluctant to receive services. One of the benefts noted by stakeholders was that staying involved 

longer would be benefcial because it would enable APS to “see the intervention through” and help 

mitigate chances of seeing the client again for the same issue. 

I like it. I was already planning to take that quote and use it and justify our stuff. Look, they 

are saying that we should try that. Happy to have that in there.” “[Longer-term intervention] 

helps with better case outcomes because if you stay involved longer and see whatever 

intervention you are putting in; you see it through. Then it doesn’t fall through the cracks and 

you get a reversal again for the referral again for the same thing. 

However, stakeholders also expressed concerns about balancing this recommendation with lack of 

funding/resources as well as clients’ right to self-determination when clients have expressed unwillingness 

to work with APS. A stakeholder noted that sometimes it must be recommended to APS to not keep cases 

open as long, in order to address incoming cases. To implement this recommendation, stakeholders 

highlighted that additional staff and funding, as well as legislative support, would therefore be needed. 

While, this is a great idea. In reality our programs are incredibly short-staffed. I second 

what she is sharing, we need funding and resources to be able to accomplish this.” “I am 

concerned a bit about balancing this with resources as well as with self-determination when 

clients have expressed unwillingness to work with APS. 

Proposed update: “In addition, APS systems should consider trying longer-term, relationship-based 

interventions for elders who are reluctant to receive services.” 

In response to this challenge, stakeholders debated whether it would be benefcial to change the wording 

of the proposed updates. Recommendations included changing the word “consider” or adding “should 

seek resources in order to ....“ In addition, the wording may need to refect that APS may refer to case 

management service (e.g., Area Agency on Aging [AAA]) to continue to support these individuals. For 

instance, the following phrase may be added: “including referrals to other agencies. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 27 

We need to consider how we are going to word that in that in a lot of jurisdictions we refer 

to more of that case management service. We don’t in adult protection at least in this state 

believe that we have the funds to keep things open indefnitely and according to best 

practice in 2012, most of the country was closing cases in 45 to 90 days but we realizes that 

there are cases that need to be open longer and we refer to AAA to provide case management 

services to those individuals. 

Stakeholders also recommended that a defnition or explanation be added to the Guidelines to clarify what 

“longer-term” means and what should be considered the “baseline.” Stakeholders also highlighted that 

the new reference to the effectiveness of Motivational Interviewing (MI) for APS is positive. The support 

could be used to encourage social workers to use MI. 

Domain 3. Receiving Reports of Maltreatment 

3B. Screening, Prioritizing, and Assignment of Screened In Reports 

No updates were proposed to this section, but stakeholders provided a recommendation for the content 

in the original Guidelines for this section. Stakeholders recommended that language be added to the 

Guidelines to clarify what a “screened-in” report is. 

Domain 4. Conducting the Investigation 

Consistent with the recommended revision for the term “investigating” in the titles for elements 2A and 

2B, stakeholders also recommended reconsidering replacing the term “investigation” with “fact-fnding 

assessment” in the title for domain 4. 

4A. Determining If Maltreatment Has Occurred 

Consistent with the recommended revision for the term “investigating,” stakeholders recommended 

considering the following revision: “The worker has been trained and is competent to investigate to 

conduct fact fnding on the particular set of circumstances described in the report (e.g., he/she has 

received training on working with nonverbal clients, with clients with intellectual disabilities, with clients 

with mental health issues, with residents of institutions, or with minority populations).” 

Stakeholders recommended adding the following items to the list of evidence typically gathered during 

investigations: “law enforcement history (e.g., 911 police calls or wellness checks),”“court records search 

history,” and “information from other sources in investigations involving persons with dementia.” 

ACL identifes a series of issues that investigators should explore before deciding whether or 

not to notify the alleged victim of the initial visit, such as preservation of individual rights and 

evidence, maximum engagement potential with the client, and victim safety. We encourage 

ACL to add to this list the need for investigators to include other sources of information in 

investigations involving persons with dementia, as they may not be accurate or reliable 

reporters due to their cognitive impairment. 
28 

Overall, stakeholders agreed with the changes for determining if maltreatment has occurred (e.g., use of MDTs 

during initial case assessment, use of standardized testing tools, training workers on the defnitions of the 

categories for case fndings). Stakeholders also noted that the different types of MDTs (e.g., forensic center, 

community awareness MDTs) could be defned in this section or in element 5B, Involuntary Intervention. 

I wonder if there is a way, and I don’t know if it is in the 5B section or another section, but 

I think that the term multidisciplinary team can be interpreted several different ways and I 

wonder if there is room for clarifcation about the types of multi-disciplinary teams. I mean 

obviously we are talking about a forensic center model here, but I think that at a basic level, 

it could be case consultation multi-disciplinary teams or more of a community awareness 

multi-disciplinary team. So, is there room within the guidelines to defne the different types? 

For item 8 (APS programs are encouraged to utilize standardized and validated decision-making tools 

and screening tools for determining whether mistreatment has occurred), stakeholders recommended 

adding the word “screening” before “decision-making” and noted that more precision in the language 

may be needed. 

For item 9 (APS workers are trained on and have a clear understanding of the defnitions of case fndings 

[for example, “confrmed” or “unfounded”]), stakeholders recommended that language be added to the 

Guidelines to clarify what the terms “confrmed” or “unfounded” mean. Stakeholders also recommended 

adding the term “inclusive” to the examples. 

4B. Conducting an APS Client Assessment 

Stakeholders recommended several revisions to the list of needs/risk assessment needs in the original 

Guidelines, including the addition of the words: “with or without a primary caregiver” to the “Care 

needs” item in the domains listed for the needs/risk assessment (“Care needs with or without a primary 

caregiver”), and the addition of “cognitive impairment” or “cognitive function” as a domain. 

Overall, stakeholders supported the new proposed guidance on using videophone technology or 

conducting virtual assessments. However, stakeholders also noted that it may need to be emphasized 

that these strategies be used when an in-person interaction is not feasible since face-to-face approaches 

should be prioritized. 

On remote access, are there fndings we might quote to say something like videoteleconferencing is a viable intervention when in-person interactions aren’t feasible? 

My concern is that we might be read to say a future in which APS abandons face-to-face 

interactions as a prioritized approach. 

4C. Investigations in Residential Care Facilities 

No updates were proposed to this section, but stakeholders provided recommendations for the content 

in the original Guidelines for this section. Specifcally, stakeholders recommended considering whether 

a defnition for “congregate settings” can be added, and they recommended that the section address the 

timing of APS coordination with law enforcement and notifcation to the Ombudsman Program when APS 

investigates in a congregate care setting. (See suggested revisions below.) 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 29 

We recommend that the section address the timing of APS coordination with law 

enforcement and notifcation to the Ombudsman Program when APS investigates in a 

congregate care setting. I.e., Under the section heading of “Background”, second paragraph, 

we recommend inserting a new sentence at the end of the paragraph: Before investigating a 

report of congregate care setting maltreatment, consultation with law enforcement about the 

timing of the APS investigation can ensure that an APS investigation does not compromise 

a law enforcement investigation that may be occurring or pending.” And “Under the section 

heading of “Background”, at the end of the third paragraph, add: When APS receives an 

allegation of maltreatment of a resident of a congregate care setting, APS shall notify the 

LTCO of the APS investigation. 

Domain 5. Service Planning and Service Implementation 

5A. Voluntary Service Implementation 

For the frst paragraph in the background section, stakeholders recommended adding the words “or their 

designated representative’s” to the following sentence: “Service plans are monitored and changes can be 

made, with the client’s or their designated representative’s involvement, to facilitate services to address 

any identifed shortfalls or newly identifed needs and risks.” 

Stakeholders recommended updating the language in this section as needed to refer to “vulnerable 

adults” instead of “elders,” to use least restrictive language, and to emphasize that the timing of the 

intervention needs to follow the pace of the client’s willingness to accept it. 

In response to the proposed update to recommend longer-term interventions for elders who are reluctant 

to receive services, stakeholders discussed the role of APS. Specifcally, they noted that there is a tension 

between the original intent and role of APS as a short-term crisis intervention program or service vs. the 

unmet needs and what APS programs see that clients really need in order to stabilize the situation (e.g., 

longer-term interventions). Stakeholders recommended that additional language could highlight that APS 

serves both purposes by more clearly using terms such as “when available/possible or where available.” 

This would also address comments here and for other sections that highlight the aspirational approach of 

the Guidelines and the limitations to implement longer case management due to resources. 

What comes up for me is the tension between the original role and intent of APS as a shortterm crisis intervention program or service.... but what we are fnding in practice is that, even 

here in the guidelines, that there are clients that have a need for longer term interventions; 

but programs generally are not funded that way. I don’t know the answer; there is a system 

gap and should APS be the program that flls that gap? So, I am coming back to the tension 

between the original intent and role of APS vs. that unmet need and what APS programs are 

seeing clients really need in order to stabilize the situation. 

I think that tension between aspirational and practical application is really important. And 

perhaps, just an idea, the guidelines could serve both purposes, if it gets called out a bit. 

Sort of “when available or where available.” So that workers are not put in the position of, 

well I am supposed to be doing this but I can’t because we don’t have the resources beyond 

the scope of what my program can provide. Whereas in other locations maybe it is a resource 

that is available. I think there is value in doing that. If there is an APS worker that is looking 

to the guidelines, I think aspiration is critical to that. 
30 

Stakeholders recommended referencing additional strategies for clients who do not have access to senior 

centers, congregate meal sites, etc., including the use of telephone or computer socialization provided 

by the Without Walls Network (e.g., DOROT University Without Walls, Well Connected, Mather Lifeways, 

and Lifetime Connections Without Walls). In addition, stakeholders recommended that language be added 

to recommend that wraparound services be provided for victims of transnational scams, including longterm case management, counseling, fnancial counseling, online or phone support groups for families and 

victims, creditor and legal help, and other interventions. 

5B. Involuntary Service Implementation 

Stakeholders highlighted their beliefs that the forensic center is just one of the models for determining 

the need for guardianship and that there are other models that may work equally well in specifc settings, 

such as rural settings. They recommended that language be added to extend determining the need for 

guardianship beyond the forensic center and to provide descriptions and defnitions of other types of MDTs. 

I like you to extent it beyond the forensic center. There may be other models that would work 

and that have not been tested yet. There may be differences in large rural areas that don’t 

have that but may come up with something that works equally well in their setting and that 

kind of thing. I like broadening it to... such as forensic centers and other multi-disciplinary 

ways to address it. 

We don’t have forensic centers as such. We have enhanced multidisciplinary team. We have 

specialty forensic services available. Not necessarily embedded in forensic teams as such. We 

sometimes use those or APS uses them to determine whether guardianship is appropriate or 

not. Forensic accountant and geriatric psychiatrist that is available to those teams. 

Other stakeholders noted some concerns regarding the wording in the proposed update for the Guidelines 

section. For example, one stakeholder noted being concerned about how safety is represented through 

guardianship and suggested adding language on client goal attainment. Other stakeholders stated that 

the update should be revised since APS may help determine whether a legal entity should be petitioned to 

determine guardianship, but APS is not the entity making the determination. 

We fully support the concept of the proposed additions regarding use of a multidisciplinary 

approach to consider whether an APS client would beneft from having a guardian or 

conservator appointed if less restrictive options are insuffcient or unavailable. However, we 

take issue with the wording of the proposed additions. State courts determine if a guardian 

or conservator is needed, applying standards set forth in state law. APS, a forensic center, 

or a group of multidisciplinary experts may help determine whether APS or another entity 

with legal authority should petition a court to appoint a guardian or conservator, but they 

do not – and cannot – “make the diffcult determination as to whether a public guardian and 

guardianship is needed.” 

Other stakeholders recommended that a reference to the American Bar Association’s PRACTICAL Tool 

be added as it aims to help lawyers identify and implement decision-making options for persons with 

disabilities that are less restrictive than guardianship. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 31 

5C. Closing the Case 

Stakeholders recommended adding language to more clearly defne what is mean by “case.” 

Thank you this is really great. The only thing I had and it is within the case closure. I felt it 

needed a bit of maybe I am over thinking it but I was thinking the defnition of case could be 

more clearly defned. There is a bit of overlap. My thinking is the case may be the hotline itself. 

And the interdictions providing during the investigation or it can be ongoing so we opened a 

protective services case. So, we are trying to utilize the same kind of reasons for closure. Tying 

it into NAMRS. That is my only comment. 

Overall, stakeholders agreed with the proposed new guidance that, as part of the case closure criteria, APS 

should consider whether the goals of the client have been attained as it allows for autonomy of the client 

and provides a person-centered approach that also aligns with research. Similar to other recommended 

practices, stakeholders noted that although this practice would be ideal, implementing it is challenging 

given limited funding/resources. They noted that more refned word such as “specifc to each client 

and resources/services available” may help address this challenge. Stakeholders also noted that goal 

attainment cannot be criteria when it includes goals that results in ongoing maltreatment by the perpetrator. 

I think this is a great message... I am going to express my concern about it. Or potential 

concern with limited funding as everyone knows off the phone with no dedicated federal 

funding just APS outside of grants or getting creative with Medicaid funding or whatever 

else you use to fund your program, I think the goals of the client to be attained, if there are 

funding issues that might be a roadblock. 

Domain 6. Training 

6A. Caseworker and Supervisor Minimum Educational Requirements 

No updates were proposed to this section, but stakeholders provided a recommendation for the content in 

the original Guidelines for this section. Specifcally, stakeholders recommended that guidance be added to 

encourage APS programs to implement adequate procedures to screen job applicants. 

APS programs must have adequate procedures in place to screen potential candidates for 

employment for suitability. APS must ensure that their employment screening procedures 

are adequate and appropriately eliminate those candidates who do not meet the minimum 

qualifcations, or whose knowledge, skills, and abilities demonstrate a lack of capability to 

work with the subject population. Additionally, candidates who fail to cooperate with the 

screening process, provide false and/or incomplete information, or fail to share disqualifying 

information must be denied employment. Stringent prerequisites are necessary in this feld, 

and should not be relaxed to fll vacant positions. 

6B. Case Worker Initial and Ongoing Training 

Overall, stakeholders recommended guidance to ensure training is standardized and consistent with 

programs’ policies. 
32 

APS should ensure training is standardized to protect the integrity of program policies and 

procedures. We favor establishing clear defnitions for case fndings, noting that adequate 

training also be provided. Without a formal, documented training program in place, the 

program will only be as good as the trainer and their memory. With a standard training 

program in place, APS programs will be assured that all training will be consistent with the 

particular program’s policies. Moreover, standard training will guarantee that variability in 

clients’ experience will be minimized. 

Stakeholders expressed support for the added guidance on using virtual reality or simulation-based 

training for caseworker training options. 

For section 1, Orientation to the Job, stakeholders recommended changing “the process for determining 

capacity” to “the process of screening for capacity” or considering use of decision-making ability instead 

of capacity, since APS workers cannot determine capacity. 

For section 3, Core Competency Training, stakeholders recommended referring readers to the training 

curriculum through San Diego State University as it would help states not have to recreate training 

content and would support consistency for certifcation. In addition, it should be considered whether 

the Guidelines could link to either NAPSA or the Academy for Professional Excellence where the Core 

Competency Training is hosted for easy access. 

I wonder if in the guidelines, and this might be a confict of interest, but I feel like a lot of 

states that may have had turn over in adult protection in previous years, may not know 

about the core curriculum offered through San Diego State University, and I know that 

is kind of a best practice or gold standard, is there any way that can be mentioned in 

the guidelines? States are not trying to recreate this based on we should be trained in 

this or that or whatever... so they could be pointed in the direction of consistency for the 

certifcate program? Because I feel like at least in the west, we have had some turn over in 

representation and I know two people have been shocked that San Diego state has the core 

competencies that they would have access to and being new to adult protection, they were 

scrambling to try to invent it come something like that already exists. 

Stakeholders also noted that item e, “Interviews with Older Adults and Caregivers,” is currently not part of 

the developed NAPSA APS Core Competency curriculum offerings and recommended providing clarifcation 

as to whether the Guidelines recommend that this course be developed. 

In terms of new training foci, stakeholders recommended adding content for training and resources on 

APS emergency preparedness and response; identifying older/vulnerable adult victims being exploited as 

“money mules” in transnational scams; applying case fnding defnitions; referrals to other agencies, state 

and federal laws, emergency relocation, and the ombudsman program; and dementia. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 33 

Given the growth of the population affected by Alzheimer’s and related dementias in the 

coming years, we strongly encourage ACL to add “dementia” to the list of training core 

competencies. Dementia training curriculum should incorporate principles of personcentered dementia care including a thorough knowledge of the person and his or her abilities 

and needs, the advancement of optimal functioning and a high quality of life, and the use 

of problem-solving approaches to care. New and existing APS personnel should be trained 

adequately and appropriately to best address the needs of the individuals they serve. 

Training should be culturally competent, both for APS workers and clients. 

For section 4, Advanced or Specialized Training, stakeholders recommended listing additional examples, 

such as advanced interviewing; advanced fnancial abuse topics; trauma-informed services; self-care 

and secondary trauma; emergency/disaster preparedness and response; working with multigenerational 

households; opioid abuse; and older adult homelessness and poverty. 

Stakeholders also recommended creating new section title 5, Certifcation Process, and moving content 

from section 4 to the new section 5. 

6C. Supervisor Initial and Ongoing Training 

Stakeholders expressed their appreciation for the added guidance on safety. However, stakeholders also 

recommended further strengthening this section using the resources developed by APS Workforce Innovations 

(APSWI), a program of the Academy for Professional Excellence, San Diego State University School of Social 

Work. (See the APS Leadership Development Report and the APS Leadership Development Framework.) 

Domain 7. APS Program Performance 

Stakeholders primarily discussed the recommendation for keeping case fles/records longer to support 

longitudinal research. Specifcally, stakeholders commented that 10–15 years may be too long and could 

be considered a liability. In addition, they noted that decisions about how long to keep case fles/records 

may depend on the outcome measure use. Stakeholders raised the question whether NAMRS case level 

data could be used for storing data over time, as an alternative to programs having to keep case records 

longer. Stakeholders also noted that the wording of the proposed update be changed to not only refer 

to keeping records with substantiated cases but also those with “inconclusive” fndings or “all cases 

regardless of fnding.” 

Stakeholders also recommended adding language to emphasize that data and fndings need to be 

“translated” for the public and decision-makers to help tell a story and help staff do their best work. 

There seems to be an underlying assumption that if data is gathered it is communicated 

and used throughout the APS/Adult Services organization and/or conveyed in a way that is 

digestible and relevant to decision-makers, older adults/families, other providers, and the 

community as a whole. Consider adding to this section the importance of APS management 

and Adult Services Administrators to not only collect the data but be able to “tell a 

compelling story” with the data. Additionally, the importance of creating a “culture of inquiry 

and outcomes”, where data is collected in the service of helping clients as well as helping 

staff do their best work. 
34 

Research Gaps 

In addition to the feedback for the actual Guidelines, stakeholders were also invited to identify research 

gaps. Specifcally, they were asked about areas for specifc APS practices and processes they had 

questions about but for which answers are not available because of a lack of research in those areas. 

Some of the most frequently mentioned research gaps focused on caseloads. Stakeholders noted lack of 

research on effective and appropriate caseload sizes for APS, including maximum number of cases APS 

staff should carry, ideal and maximum supervisor-to-staff ratios, and the impact of geography, distance, 

and complexity on caseload issues. 

Stakeholders also noted that much of the research is focused on the older adult population, and more 

research is needed that addresses the full spectrum of the APS population, including individuals with 

intellectual and development disabilities. In addition, stakeholders noted that additional research on 

perpetrators is needed. Research areas include the prosecution rate of perpetrators and the question of 

how those rates may affect the number of perpetrators going from adult to adult (“e.g., would more legal 

work in prosecuting perpetrators lead to a decrease in maltreatment?”). 

It was also highlighted that more research is needed on the effectiveness of different APS models, 

practices, program designs, and services used in different states and counties, and the impact of these 

on APS outcomes, including re-referral, prosecution, and client safety. Specifcally, stakeholders were 

interested in research on 

• whether there are specifc services that would have the most impact on outcomes;

• relationship-based interventions and whether there are subsets of populations that would most

beneft from those interventions;

• how limited resources such as in “resource deserts” in rural areas affect outcomes;

• the collaboration between the client and APS worker and what strategies can enhance that collaboration, including for clients with cognitive limitations; and

• effective case management strategies for self-neglect.

Stakeholders also identifed research gaps related to training of APS staff. Specifcally, stakeholders noted 

that more research is needed on the effective timing of on-going training, including how many additional or 

specialized trainings an APS professional and supervisor should receive on an annual basis. More research 

is also needed on different training modalities and/or evidence-based strategies and mentorship programs 

used by different states and counties. 

• Other identifed research gaps included research on

• fnancial exploitation and outcome measures on interventions to mitigate risk for fnancial exploitation; 

• how APS should intervene with clients with declining capacity;

• the cost of staff attrition;

• quality assurance (QA) for APS programs, what QA should entail, and effective QA tools and data

elements; and

• how states are are implementing the Guidelines to conduct state comparisons (“National Core

Indicators data type information”).
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 35 

Solicitation of Feedback for Future Updates 

Stakeholders were also invited to provide suggestions for how ACL may solicit feedback and comments 

from stakeholders for future updates to the Guidelines. Stakeholders noted that they appreciated the 

format used for the current updating process, which included the option to leave written comments on 

the RFI Web page and to participate on the webinars. Other suggested methods included presenting at 

the NAPSA conference and state conferences, using surveys, and reaching out directly to APS leaders. 

Stakeholders also noted that soliciting stakeholder feedback could be made “more of an event” using a 

multiphased approach. 

Format of the Guidelines 

Stakeholders were asked to also comment on the format of the Guidelines and ways the document can be 

made more user-friendly and accessible. They noted that a shorter version that includes links to resources 

and programs would be useful. In addition, stakeholders noted that it would be useful to have links to 

cited research and also links to sections within the document for easier navigation. 

Dissemination of the Guidelines 

Stakeholders provided several suggestions for disseminating the updated Guidelines to ensure they 

reach key stakeholders who can beneft from the Guidelines and implement the recommended practices. 

Specifcally, they recommended giving presentations at ACL and on NAPSA regional calls, holding 

webinars, providing online trainings, sending the updated Guidelines directly to states and APS programs, 

and sending them via national listservs. In addition, stakeholders recommended establishing a schedule 

for future updates, including publishing the Guidelines during a designated month so stakeholders can 

anticipate the updates. 

6. Technical Expert Panel

Purpose 

The purpose of the TEP was to refne revisions and build consensus for the changes to the Guidelines 

based on the proposed updates and feedback from stakeholders. The TEP consisted of nine experts, 

representing APS program leaders and researchers (see Appendix B). 

Methods 

TEP members were invited to participate in fve virtual meetings, each lasting 90 minutes. Prior to the frst 

meeting, TEP members received the annotated bibliography of the new research to be considered as well 

as a copy of the Guidelines that included all proposed updates in track changes and comments showing 

the feedback received from stakeholders for each domain/element. To facilitate the revision process, the 

project team integrated feedback that was considered noncontroversial (i.e., small word changes) prior to 

the meetings, but noted those changes for the TEP to confrm whether they agree with the changes. For all 

other feedback, the team noted specifc questions for the TEP, which were then discussed during the virtual 

meetings. The marked-up document was used during the TEP meetings via screen share, with changes 

being made during the meeting as feasible. 
36 

 

Stakeholder feedback was discussed with the TEP in order by domain/element, starting with domain 1. 

After each meeting, the TEP received a summary of key decisions and an updated copy of the Guidelines 

showing the decisions. The updated copy was then used in the next meeting. TEP members also had an 

opportunity to comment on the decisions in writing, to note objections or suggest additional changes. 

Results 

As a result of discussions during virtual meetings, TEP members reached agreement about whether to 

make changes or not in response to stakeholder recommendations. TEP members also recommended 

revisions that were not related to stakeholder feedback (see Table 5). 

Table 5. Types of Decisions Made by TEP 

Decisions by TEP 

Number of 

Instances 

Agreed with stakeholder recommendation and implemented recommendation 29 (36%) 

Agreed with stakeholder recommendation but implemented recommendation with 

additional revisions or alternative approach 17 (21%) 

Did not agree with stakeholder recommendation and did not implement revision 19 (23%) 

Recommended and implemented revision/addition not related to stakeholder feedback 16 (20%) 

The following section provides a summary of key recommendations11 from the TEP. 

TEP Recommendations in Response to Stakeholder Feedback 

As a result of stakeholder feedback, TEP members made the following global recommendations for revisions: 

• Create a glossary with defnitions of terms used in the Guidelines to assist the reader of the

Guidelines only; defnitions do not represent universal defnitions for the APS feld.

• Change the word “victim” to “alleged victim” or “client” as appropriate.

• Keep the term “maltreatment” rather than changing it to abuse and/or self-neglect as it is

consistent with ACL practice (e.g., NAMRS).

• Do not add new content regarding all APS adult populations, including those with dementia,

since the current Guidelines are clear as to the population served by APS; agreed to look for

opportunities to include people with dementia throughout.

As a result of stakeholder feedback, TEP members made the following recommendations for revising 

content in specifc domains/elements: 

• Agreeing with stakeholder feedback:

 1B. Protecting Program Integrity: Add content on “providing information on rights of alleged

victims and alleged perpetrators.”

11 The recommendations presented in this section are examples for illustration and do not present all recommendations 

provided by the TEP. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 37 

 1H. Staffng Resources: Add additional content to provide guidance regarding what to

consider for worker-to-supervisor ratios.

 2C. Closing the Case: Add “client has died”; add “having achieved goals to the extent feasible.” 

 6C. Supervisor Training: Add content from the APS Leadership Development report to

bolster this element.

 Conducting the Investigation: Do not change “Investigation” to “Fact Finding/

Assessment.”

• Not agreeing with stakeholder feedback:

 6B. Caseworker Initial and Ongoing Training: Do not add suggested examples for advanced

or specialized trainings.

TEP Recommendations Not Related to Stakeholder Feedback 

TEP members also provided recommendations for revisions and additional language that were not in 

response to stakeholder feedback. These included: 

• Add language in the introduction and a footnote to clarify why references to child protective

services/child welfare are included; repeat footnote for every instance.

• Add language in the introduction that highlights that the Guidelines refect the most recent evidence and best practices, and that ACL did not draw from current state laws or regulations to avoid

limiting the Guidelines.

• Add NAMRS data and defnitions to the background sections; add note highlighting that states’

defnitions may vary.

• Move the content on “trauma-informed approach” from domain 1A, Ethical Foundation of APS

Practice, to domain 4, Conducting the Investigation.

• Move 1G, Protecting Program Integrity, up closer to 1A, Ethical Foundation, and add a “bridge”

sentence.

• Revise terms:

 5A/B. Voluntary/Involuntary Intervention: Change “Intervention” to “Service Implementation.” 

 4C. Investigations in Congregate Care Settings: Change “congregate care setting” to

“residential care facility,” and add defnition to glossary.

 4D. Completion of Investigation and Substantiation Decision: Rename “Substantiation

Decision” to “Finding.”

• Consolidate content:

 4B. Conducting an APS Client Assessment: Consolidate the list of domains in the needs/risk

assessment.

• Add new content:

 7. Evaluation/Program Performance: Change domain name to Quality Assurance and

separate content into 7A, Evaluating Program Performance, and 7B, Program Data.
38 

7. Considerations and Recommendations for Future Updates

The process followed in updating the Guidelines—considering new research, stakeholder input, and expert 

feedback—has improved the content and level of detail of the Guidelines. In addition, these activities have 

yielded important considerations and recommendations for future updates. These considerations and 

recommendations include: 

• Literature Updates:

 In addition to reviewing published peer-reviewed journal articles, consider reviewing key

materials from other reliable sources (e.g., NAMRS, NAPSA, National Center on Elder Abuse

[NCEA]) to help inform updates to the Guidelines.

 Engage TEP members before the literature search to obtain their suggestions regarding

reliable sources that should be reviewed.

• Content Updates:

 For domain 6B, Caseworker Initial and Ongoing Training, consider creating a list of training

topics that would constitute minimum training for new APS workers.

 As the body of APS research grows, consider removing references for studies from child

welfare and child protective services.

• Supplemental Materials:

 Consider developing a separate compendium of resources with links to specifc outside

programs and materials. This compendium could be a useful resource for the feld, which

has suggested the value of linking. ACL has stated that links to outside resources should

not be included in the Guidelines to avoid turning it into a resource document rather than

Guidelines; a separate resource compendium could address the recommendation/need

expressed by the feld, however.

 Consider publishing annually or biennially an annotated bibliography that summarizes new

research to provide the APS feld with interim updates of relevant APS research before the

Guidelines are updated.
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 39 

Appendix A. List of Domains and Elements 

1. Program Administration

1A. Ethical Foundation of APS Practice

1B. Protecting Program Integrity 

1C. Defnitions of Maltreatment 

1D. Population Served 

1E. Mandatory Reporters 

1F. Coordination With Other Entities 

1G. Program Authority, Cooperation, Confdentiality and Immunity 

1H. Staffng Resources 

1I. Access to Expert Resources 

1J. Case Review-Supervisory Process 

1K. Worker Safety and Well-being 

1L. Responding During Community Emergencies 

1M. Community Outreach and Engagement 

1N. Participating in Research 

2. Time Frames

2A. Responding to the Report

2B. Completing the Investigation 

2C. Closing the Case 

3. Receiving Reports of Maltreatment

3A. Intake

3B. Screening, Triaging, and Assignment of Screened-in Reports 

4. Conducting the Investigation

4A. Determining If Maltreatment Has Occurred

4B. Conducting a Psychosocial Assessment 

4C. Investigations in Residential Care Facilities 

4D. Completion of Investigation and Findings 

5. Service Planning and Service Implementation

5A. Voluntary Service Implementation

5B. Involuntary Service Implementation 

5C. Closing the Case 

6. Training

6A. Case Worker and Supervisor Minimum Educational Requirements

6B. Case Worker Initial and Ongoing Training 

6C. Supervisor Initial and Ongoing Training 

7A. 

7. APS Program Performance

Managing Program Data 

7B. Evaluating Program Performance 
40 

Appendix B. Technical Expert Panel 

Georgia Anetzberger, PhD, ACSW 

Consultant in private practice 

Fellow, Gerontological Society of America 

Adjunct Assistant Professor, Department of 

Medicine at Case Western Reserve University 

Cleveland, OH 

Catherine Bingle 

Research Specialist, Adult Protective Services, 

Texas Department of Family and 

Protective Services 

Austin, TX 

Julie Bobitt, PhD 

Director, Interdisciplinary Health Sciences, 

College of Applied Health Sciences, 

University of Illinois at Urbana Champaign 

Champaign, IL 

Akiles Ceron, MSW 

Director, Adult Protective Services, Department 

of Aging and Adult Services, City and County 

of San Francisco 

San Francisco, CA 

Robert Cosby, MSW, MPhil, PhD 

Associate Professor; Director, Multidisciplinary 

Gerontology Center, Howard University, 

School of Social Work 

Washington, DC 

Michael Hagenlock, LCSW, LAC 

APS Bureau Chief, Montana Department of 

Public Health & Human Services 

Helena, MT 

Rachel Lakin, MSW 

Adult Protection Program Administrator, 

New Hampshire Department of Health and 

Human Services 

Concord, NH 

Geoffrey Rogers 

Director of Learning and Development, 

Brookdale Center for Healthy Aging 

Peggy Rogers 

Manager, Adult Mistreatment Prevention and 

Response Section, Adult Protective Services 

and Colorado Adult Protective Services data 

system (CAPS) Check Unit, Colorado 

Department of Human Services 

Denver, CO 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 41 

Appendix C. Included Articles in Updates by Guidelines Domain/Element 

Note: Articles may be relevant to more than one domain and, therefore, may be listed more than once. 

1. Program Administration

Guideline Element Journal Article Reference 

1C. Defnitions of Maltreatment Mosqueda, L., Wiglesworth, A., Moore, A. A., Nguyen, A., Gironda, M., 

& Gibbs, L. (2016). Variability in fndings from adult protective services 

investigations of elder abuse in California. Journal of Evidence-Informed 

Social Work, 13(1), 34-44. 

1E. Mandatory Reporting Lees, K. (2018). Elder mistreatment: An examination of formal and informal 

responses to a growing public health concern (Doctoral dissertation). 

Retrieved from https://repository.library.northeastern.edu/fles/ 

neu:cj82r9210 

1E. Mandatory Reporting Mathews, B., Lee, X. J., & Norman, R. E. (2016). Impact of a new mandatory 

reporting law on reporting and identifcation of child sexual abuse: A seven 

year time trend analysis. Child Abuse & Neglect, 56, 62-79. 

1F. Coordination With 

Other Entities 

Gassoumis, Z. D., Navarro, A., & Wilber, K. H. (2015). Protecting victims of 

elder fnancial exploitation: The role of an elder abuse forensic center in 

referring victims for conservatorship. Aging & Mental Health, 19(9), 790-798. 

1F. Coordination With Other 

Entities 

Rizzo, V. M., Burnes, D., & Chalfy, A. (2015). A systematic evaluation of a 

multidisciplinary social work–lawyer elder mistreatment intervention model. 

Journal of Elder Abuse & Neglect, 27(1), 1-18. 

1F. Coordination With Other 

Entities 

Sirey, J. A., Berman, J., Depasquale, A., Halkett, A., Raeifar, E., Banerjee, 

S., ... Raue, P. J. (2015). Feasibility of integrating mental health screening 

and services into routine elder abuse practice to improve client outcomes. 

Journal of Elder Abuse & Neglect, 27, 254-269. 

1F. Coordination With Other 

Entities 

Wilber, K. H., Navarro, A. E., & Gassoumis, Z. D. (2014). Evaluating the 

elder abuse forensic center model. Retrieved from https://www.ncjrs.gov/ 

pdffles1/nij/grants/246428.pdf 

1F. Coordination With Other 

Entities 

1I. Access to Expert Resources 

He, A. S., & Phillips, J. (2017). Interagency collaboration: Strengthening 

substance abuse resources in child welfare. Child Abuse & Neglect, 64, 

101-108.

1I. Access to Expert Resources Brink, F. W., Thackeray, J. D., Bridge, J. A., Letson, M. M., & Scribano, P. 

V. (2015). Child advocacy center multidisciplinary team decision and its

association to child protective services outcomes. Child Abuse & Neglect,

46, 174-181.

1I. Access to Expert Resources Burnett, J., Dyer, C. B., Clark, L. E., & Halphen, J. M. (2018). A statewide elder 

mistreatment virtual assessment program: Preliminary data. Journal of the 

American Geriatrics Society. doi: 10.1111/jgs.15565. [Epub ahead of print] 

1K. Worker Safety and Well-Being Ghesquiere A., Plichta, S. B., McAfee, C., & Rogers, G. (2018). Professional 

quality of life of adult protective service workers. Journal of Elder Abuse & 

Neglect, 30(1), 1-19. 

1M. Community Outreach and 

Engagement 

Acierno, R. (2018). National Elder Mistreatment Survey: 5 Year Follow-up 

of Victims and Matched Non-victims. National Institute of Justice (NIJ). 

Retrieved from: https://www.ncjrs.gov/App/Publications/abstract. 

aspx?ID=274251 
42 

 

Guideline Element Journal Article Reference 

1M. Community Outreach and 

Engagement 

Susman, A., Lees, K. E., & Fulmer, T. (2015). Understanding repeated visits to 

adult protective services. The Journal of Adult Protection, 17(6), 391-399. 

2. Time Frames 

Guideline Element Journal Article Reference 

2C. Closing the Case Mariam, L. M., McClure, R., Robinson, J. B., & Yang, J. A. (2015). Eliciting 

Change in At-Risk Elders (ECARE): Evaluation of an elder abuse intervention 

program. Journal of Elder Abuse & Neglect, 27, 19-33. 

3. Receiving Reports of Maltreatment 

Guideline Element Journal Article Reference 

No articles identifed 

4. Conducting the Investigation 

Guideline Element Journal Article Reference 

4A. Determining If Maltreatment 

Has Occurred 

Beach, S. R., Liu, P.-J., DeLiema, M., Iris, M., Howe, M. J. K., & Conrad, K. J. 

(2017). Development of short-form measures to assess four types of elder 

mistreatment: Findings from an evidence-based study of APS elder abuse 

substantiation decisions. Journal of Elder Abuse and Neglect, 29(4), 229-253. 

4A. Determining If Maltreatment 

Has Occurred 

Brink, F. W., Thackeray, J. D., Bridge, J. A., Letson, M. M., & Scribano, P. 

V. (2015). Child advocacy center multidisciplinary team decision and its 

association to child protective services outcomes. Child Abuse & Neglect, 46, 

174-181 

4A. Determining If Maltreatment 

Has Occurred 

Conrad, K. J., Iris, M., & Liu, P.-J. (2017). Elder Abuse Decision Support 

System: Field test outcomes, abuse measure validation, and lessons learned. 

Journal of Elder Abuse and Neglect, 29(2-3), 134-156. 

4A. Determining If Maltreatment 

Has Occurred 

Wilber, K. H., Navarro, A. E., & Gassoumis, Z. D. (2014). Evaluating the 

elder abuse forensic center model. Retrieved from https://www. ncjrs.gov/ 

pdffles1/nij/grants/246428.pdf 

4B. Conducting a Psychosocial 

Assessment 

Burnett, J., Dyer, C. B., Clark, L. E., & Halphen, J. M. (2018). A statewide elder 

mistreatment virtual assessment program: Preliminary data. Journal of the 

American Geriatrics Society. doi: 10.1111/jgs.15565. [Epub ahead of print] 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 43 

 

5. Service Planning and Service Implementation 

Guideline Element Journal Article Reference 

5A. Voluntary Service 

Implementation 

Acierno, R., Hernandez-Tejada, M. A., Anetzberger, G. J., Loew, D., & Muzzy, 

W. (2017). The national elder mistreatment study: An 8-year longitudinal 

study of outcomes. Journal of Elder Abuse & Neglect, 29(4), 254-269. 

5A. Voluntary Service 

Implementation 

Burnes, D. P. R, Rizzo, V. M., & Courtney, E. (2014). Elder abuse and neglect 

risk alleviation in protective services. Journal of Interpersonal Violence, 

29(11), 2091-2113. 

5A. Voluntary Service 

Implementation 

Jackson, S. L., & Hafemeister, T. L. (2014). How case characteristics 

differ across four types of elder maltreatment: Implications for tailoring 

interventions to increase victim safety. Journal of Applied Gerontology, 33(8), 

982-997. 

5A. Voluntary Service 

Implementation 

Mariam, L. M., McClure, R., Robinson, J. B., & Yang, J. A. (2015). Eliciting 

Change in At-Risk Elders (ECARE): Evaluation of an elder abuse intervention 

program. Journal of Elder Abuse & Neglect, 27, 19-33. 

5A. Voluntary Service 

Implementation 

Sirey, J. A., Berman, J., Depasquale, A., Halkett, A., Raeifar, E., Banerjee, S., 

... Raue, P. J. (2015). Feasibility of integrating mental health screening and 

services into routine elder abuse practice to improve client outcomes. Journal 

of Elder Abuse & Neglect, 27, 254-269. 

5B. Involuntary Service 

Implementation 

Gassoumis, Z. D., Navarro, A., & Wilber, K. H. (2015). Protecting victims of 

elder fnancial exploitation: The role of an elder abuse forensic center in 

referring victims for conservatorship. Aging & Mental Health, 19(9), 790-798. 

5C. Closing the Case Burnes, D., Connolly, M. T., Hamilton, R., & Lachs, M. S. (2018). The feasibility 

of goal attainment scaling to measure case resolution in elder abuse and 

neglect adult protective services intervention. Journal of Elder Abuse & 

Neglect, 30(3), 209-222. 

6. Training 

Guideline Element Journal Article Reference 

6B. Case Worker Initial and 

Ongoing Training 

Du Mont, J., Kosa, D., Yang, R., Solomon, S., & Macdonald, S. (2017). 

Determining the effectiveness of an Elder Abuse Nurse Examiner Curriculum: 

A pilot study. Nurse Education Today, 55, 71-76. 

6B. Case Worker Initial and 

Ongoing Training 

Mosqueda, L., Wiglesworth, A., Moore A. A., Nguyen, A., Gironda, M., 

& Gibbs, L. (2016). Variability in fndings from adult protective services 

investigations of elder abuse in California. Journal of Evidence-Informed 

Social Work, 13(1), 34-44. 

6B. Case Worker Initial and 

Ongoing Training 

Pickering, C. E. Z., Ridenour, K., Salaysay, Z., Reyes-Gastelum, D., & Pierce, 

S. J. (2018). EATI Island – A virtual-reality-based elder abuse and neglect 

educational intervention. Gerontology & Geriatrics Education, 39(4), 445-463. 

6B. Case Worker Initial and 

Ongoing Training 

Storey, J. E., & Prashad, A. A. (2018). Recognizing, reporting, and responding 

to abuse, neglect, and self-neglect of vulnerable adults: An evaluation of 

the re:act adult protection worker basic curriculum. Journal of Elder Abuse & 

Neglect, 30(1), 42-63. 

6C. Supervisor Initial and 

Ongoing Training 

Ghesquiere A., Plichta, S. B., McAfee, C., & Rogers, G. (2018). Professional 

quality of life of adult protective service workers. Journal of Elder Abuse & 

Neglect, 30(1), 1-19. 
44 

 

7. APS Program Performance 

Guideline Element Journal Article Reference 

7. APS Program Performance Booker, J. G., Breaux, M., Abada, S., Xia, R., & Burnett, J. (2018). Assessment 

of older adults’ satisfaction with adult protective services investigation and 

assistance. Journal of Elder Abuse & Neglect, 30(1), 64-74. 

7. APS Program Performance Burnes, D. P. R, Rizzo, V. M., & Courtney, E. (2014). Elder abuse and neglect 

risk alleviation in protective services. Journal of Interpersonal Violence, 

29(11), 2091-2113. 

7. APS Program Performance Burnes, D., Connolly, M. T., Hamilton, R., & Lachs, M. S. (2018). The feasibility 

of goal attainment scaling to measure case resolution in elder abuse and 

neglect adult protective services intervention. Journal of Elder Abuse & 

Neglect, 30(3), 209-222. 

7. APS Program Performance Susman, A., Lees, K. E., & Fulmer, T. (2015). Understanding repeated visits to 

adult protective services. The Journal of Adult Protection, 17(6), 391-399. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 45 

 

Appendix D. Verbatim Public Comments by Domain and Elements 

Note: Comments below are unedited, quoted exactly as written by stakeholders who provided feedback. 

Domain 1. Program Administration 

Element Comment 

1A. Ethical Foundation of APS 

Practice 

Consider adding: “Code of Ethics and policies should be reviewed annually” 

1A. Ethical Foundation of APS 

Practice 

1G. Program Authority, 

Cooperation, Confdentiality, 

and Immunity 

APS represents nursing homes/assisted living facilities. The facility calls APS 

against family members [wishes?] and when a senior would like to return to 

the community; however, if a family member has a complaint against a facility 

it is considered a “business” issue. APS petitions for guardianships at the 

direction of assisted living facilities. APS refuses to comply with the American 

for Disabilities Act when it comes to seniors with hearing issues and vision 

issues. In our situation APS refused to investigate the medically unnecessary 

use of morphine by a facility. If APS at the request of a facility can restrict 

family members from medical records, care and transitioning out of a facility, 

then APS is representing the facility. We do not understand why an agency 

that is supposed to protect our seniors is instead representing a private 

industry and support staff: i.e., nursing homes/guardians and support staff. 

We also do not understand why seniors are NOT protected by the Americans 

with disability act. Thus, respectfully we suggest as guidelines that APS be 

required to comply with American with Disabilities Act, that APS no longer 

be the agency that nursing homes call for assistance, that APS represent 

the patient not the facility, and that a separate unit be set up to deal with 

drug abuse by facilities. We would also like to see competency tests done by 

licensed professionals. Above all APS should put the patient frst. 

1B. Protecting Program Integrity Add underlined text: “It is recommended that APS systems create and 

implement policies to ensure that the APS program is held to high standards 

or integrity. APS program policy and standards should be transparent and 

available to the public. Policies are needed to address the issues below:” 

Suggest the following revisions: “Client rights: At the time of the initial 

interview with that person, APS programs should provide an explanation of 

APS program and goals, and the client’s rights, in terms that are reasonably 

understandable to the adult who is the subject of the investigation who may 

have experienced maltreatment.” 

Suggest adding the following [paragraph]: “Rights of person alleged 

responsible for maltreatment: At the time of the initial interview with that 

person, APS programs should provide an explanation of APS program 

and goals, and the rights of the person, in terms that are reasonably 

understandable to the adult who is the subject of the investigation.” 

1B. Protecting Program Integrity Consider adding content regarding developing a confict of interest form 

and policies and procedures that provide remedies for conficts whenever 

possible. 

1C. Defnitions of Maltreatment We recommend that the guideline be revised as follows [add underlined 

sentence]: "It is recommended that APS systems defne and respond 

to, at a minimum, reports of the following categories of maltreatment: 

physical, emotional, and sexual abuse; fnancial exploitation; neglect; and 

self-neglect. APS system should establish clear defnitions for the terms 

"confrmed," inconclusive," and "unfounded," and provide training to its 

employees on these defnitions, as well as how cases should be assigned to 

the different categories." 
46 

Element Comment 

1D. Population Served APS nationally could provide guidance on working with these victims [victims 

of transnational scams] in safety planning to mitigate against further losses or 

contact with the scammers. In addition, several states currently don’t include 

these victims in the types of cases that state or local APS may investigate 

or assist. Their state regulations either do not allow for assisting in fnancial 

exploitation that is not by someone locally (or a trusted position) or they are 

not seen as in ‘imminent danger’. Yet, we know that undue infuence, and age 

associated fnancial vulnerability, mild cognitive impairment and the various 

dementia’s, as well as depression and loneliness can make older adults more 

susceptible, and cause them to lose their life savings. 

1D. Population Served We were grateful for the opportunity to comment on the 2016 National 

Voluntary Consensus Guidelines for State APS Systems during their 

development. At that time, we offered a variety of suggestions as to how APS 

systems can identify and work with persons living with dementia. However, 

ACL declined to incorporate these suggestions or specifcally identify this 

particularly vulnerable population. While we understand the need for these 

guidelines to remain broadly applicable, every state across the country is 

expected to experience an increase of at least 12 percent in the number of 

people with Alzheimer’s between 2019 and 2050 and working with these 

individuals can be fundamentally different from working with other APS 

clients. For example, persons living with dementia often have diffculty 

understanding or explaining situations and their behaviors may be viewed 

by APS personnel as uncooperative, disruptive, or combative. Therefore, 

we encourage ACL to identify this population specifcally throughout the 

updated guidelines. 

1E. Mandatory Reporters Suggest changing “Victim service providers” under Guideline to “Crime 

victim service providers” 

1E. Mandatory Reporters We are supportive of exemptions to the mandatory reporting requirements 

that are informed by professional licensing standards, as well as state and 

federal laws that would exempt certain categories of professionals from 

mandatory reporting. 

1E. Mandatory Reporters Current 2016 guidelines (1d: Mandatory Reporters) recommend that “f) 

victim services providers” be included as a mandated reporter in state law. 

Although this recommendation is from the existing guidelines and not part of 

the 2019 update, it should be reconsidered and removed. 

1E. Mandatory Reporters APS staff should be informed that long-term care ombudsmen are not 

mandatory reporters. 

1E. Mandatory Reporters We recommend that guidance clearly indicate that representatives of the 

State Long-Term Care Ombudsman Program are not mandatory reporters. 

1E. Mandatory Reporters Under the section heading of “Guideline”, we recommend that a reference 

to the Ombudsman Program is added to the second sentence such as [this 

underlined addition]: “Exemptions to mandatory reporting requirements, 

such as the exemption of representatives of the Offce of the State Long-Term 

Care Ombudsman, should be consistent with...”. Given our closely-linked 

services with APS, and because the Ombudsman Program is a program of 

the Older Americans Act and overseen by ACL, it is important to specify that 

representatives of the Offce are not mandatory reporters. 

1E. Mandatory Reporters Change item j): 

j) “Anyone engaged in the care of a vulnerable adult.” to 

j) “Anyone engaged in the care of or providing services to a vulnerable 

adult.” 

1E. Mandatory Reporters Suggest adding ‘civil and criminal’ to immunity protection. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 47 

 

Element Comment 

1F. Coordination With Other 

Entities 

Having suggested in 2015 that it would be benefcial to add civil legal 

services providers to the list of organizations or agencies with which APS 

should coordinate, we commend ACL for proposing to include these crucial 

advocates for victims now. Their knowledge about legal tools for preventing, 

detecting, and remedying adult maltreatment is greatly needed by APS and 

in multidisciplinary efforts. 

1F. Coordination With Other 

Entities 

I think that long-term care ombudsmen need to be added to the agency 

coordination list. 

1F. Coordination With Other 

Entities 

We recommend that the Ombudsman Program is added to the list of agencies 

and providers with which APS should develop an MOU or similar agreement. 

1F. Coordination With Other 

Entities 

We support the addition of Memoranda of Understanding, cross-training, 

and co-location in the Guidelines, with several important caveats that are 

critical to the State Long-Term Care Ombudsman [SLTCO] program fulflling 

its mandate under the Older Americans Act. While the SLTCO is in favor of 

collaboration to produce best outcomes, it is important to note that the 

suggestion to co-locate APS and SLTCO staff is currently an organizational 

confict of interest under Section 712 of the Older Americans Act. It is evident 

in the original text of the OAA and its subsequent reauthorizations that 

Congress contemplated residents of long-term care facilities would be best 

served by ombudsmen who are focused, independent advocates; therefore, 

Congress included language to prohibit conficts of interest at both the 

individual and organizational level. Section 712(f)(2)(A)(vi) of the Older 

Americans Act speaks specifcally to this issue, and identifes co-location of 

the SLTCOP with an organization that provides adult protective services as 

an organizational confict of interest. The regulations promulgated by DHHS 

to administer the OAA codify that co-locating the SLTCOP and APS is an 

organizational confict of interest. 

1F. Coordination With Other 

Entities 

The Guideline should specifcally include the SLTCO as an agency with whom 

a Memorandum of Understanding should be developed in order to best serve 

those APS clients during investigations and interventions. 

1F. Coordination With Other 

Entities 

Consider adding: “Attorney General; Protection and Advocacy Organizations; 

Long-Term Care Ombudsman Program; Licensing and Certifcation 

Organization; Local and State AAA or Department of Aging; Department of 

Disabilities”. Policies should be developed to work with the ombudsman 

program and licensing and certifcation organization. In addition, policies 

should be developed to make referrals to other agencies when needed. 

1F. Coordination With Other 

Entities 

What about Crisis Intervention Team using Law Enforcement? 

1F. Coordination With Other 

Entities 

I wonder if there is a way, and I don’t know if it is in the 5B section or another 

section, but I think that the term multidisciplinary team can be interpreted 

several different ways and I wonder if there is room for clarifcation about 

the types of multi-disciplinary teams. I mean obviously we are talking about 

a forensic center model here, but I think that at a basic level, it could be case 

consultation multi-disciplinary teams or more of a community awareness 

multi-disciplinary team. So, is there room within the guidelines to defne the 

different types? 

1F. Coordination With Other 

Entities 

Is there anything being done to ‘improve APS response nationally in assisting 

each state’s APS in regards to assisting older and other vulnerable adult 

victims (and their families) of transnational scams. This would include the 

importance of mandating that APS additionally fle an IC3.gov and FTC.gov 

report in addition to cross reporting to local law enforcement, especially 

where the victim (or family member) is unable or unwilling. 
48 

 

 

Element Comment 

1F. Coordination With Other 

Entities 

Makes sense to me! / Good changes. Consistent with literature. 

1F. Coordination With Other 

Entities 

I fnd the update appropriate and needed. 

1G. Program Authority, 

Cooperation, Confdentiality, 

and Immunity 

“Communication and cooperation: In order to detect, prevent, and remedy 

adult maltreatment, it is recommended that APS systems be given the 

authority to cooperate with and share information related to an APS case 

with:” Suggest Adding: 

3) “informal support persons and licensed providers.” 

As a social service program APS must be able to identify and engage 

informal and formal supports with person’s consent and also have the 

ability to do so in limited circumstances when capacity is at issue in order to 

develop supported decisions makers for the person. 

1G. Program Authority, 

Cooperation, Confdentiality, 

and Immunity 

This guideline does not provide guidance when it is the vulnerable or 

older adult who is refusing access. Suggest [adding underlined text]: “It is 

recommended that APS systems be given the authority to access alleged 

victims of maltreatment and the authority to prevent another’s interference 

in an APS case, including access of the older or vulnerable adult. That access 

includes the authority to conduct a private, face-to-face interview with the 

alleged victim.” 

1G. Program Authority, 

Cooperation, Confdentiality, 

and Immunity 

For “Communication and cooperation”, consider adding: 

4) “Non-APS members including ombudsman program and licensing and 

certifcation organization.” 

1H. Staffng Resources Add the word “periodic” to this sentence: “To reach that goal, it is 

recommended that APS systems conduct periodic caseload studies to 

determine and implement manageable ratios” 

Add the word “suggested” to this sentence: “Finally, it is recommended that 

there be a suggested limit on the number of workers supervised by each 

supervisor.” 

Add the words “or guardianship” to this sentence: “differences in complexity 

of allegations (e.g., many fnancial exploitation cases and self-neglect or 

guardianship cases take signifcant time and expertise). 

1I. Access to Expert Resources I fnd the update appropriate and needed. 

1I. Access to Expert Resources 

Assessment of APS clients may have signifcant legal ramifcations. 

Therefore, we support testing the use of technology (or other models) that 

enhance and facilitate APS client assessment by well-qualifed experts. 

1I. Access to Expert Resources 

Consider adding: “Elder law; substance use; fnancial exploitation; and longterm care” as topics. 

1K. Worker Safety and Well-Being Much appreciated added guidance on safety!! 

1K. Worker Safety and Well-Being Add the words “and training” to this sentence: “It is recommended that APS 

systems create policies and protocols, and provide adequate resources and 

training related to worker safety.” 

Add the words “or client” to item number 7: “Workers should never be 

required to respond to a situation that would put the worker or client at risk 

without adequate safety supports available.” 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 49 

 

Element Comment 

1L. Responding During Community 

Emergencies 

[Recommend adding guidance regarding the] development of a national 

working group to develop policies, protocols and trainings on APS 

Emergency Preparedness and Response. Add training and related resources 

to Core Competency Training for APS Workers and Supervisors. 

1L. Responding During Community 

Emergencies 

Consider adding guidance for establishing a process for the role of APS in 

emergency relocations of facility residents (assisted living, nursing home, 

and other settings) 

1M. Community Outreach and 

Engagement 

Consider utilizing research on public perceptions of aging, ageism, and 

elder abuse and how to use communication tools developed by Frameworks 

Institute, NCEA and eight other national aging organizations for the 

Reframing Elder Abuse Project. 

Domain 2. Time Frames 

Element Comment 

2A. Responding to the Report/ 

Initiating the Investigation 

Investigation is inconsistent with a social service program when the older 

or vulnerable adult is the subject or when a primary support person in 

relationship with the older or vulnerable adult is the subject. Suggest 

assessment for neglect and/or fact-fnding assessment for abuse and 

exploitation. Change to “2A. Responding to the report/initiating Fact 

Finding/Assessment”. 

2B. Completing the Investigation Investigation is inconsistent with a social service program when the older 

or vulnerable adult is the subject or when a primary support person in 

relationship with the older or vulnerable adult is the subject. Suggest 

assessment for neglect and/or fact-fnding assessment for abuse and 

exploitation. Change to “2B. Completing the Assessment”. 

2B. Completing the Investigation Add the words “with supervisory approval” to this guideline: “allow for 

extensions for good cause with supervisory approval.” 

2C. Closing the Case Add “the client had died” to the list of criteria for case closure. 

2C. Closing the Case Right before the call I looked over the document that was in the e mail 

blast about the webinars and updates and the recommendations about the 

possibility of monitoring cases longer term... I agree with it and I think it is a 

great idea. I just know from working with the APS programs over the years that 

it is a real challenge to work with clients for long periods of time when you are 

doing an investigation. That part made me a bit uneasy because I know that is 

going to be very diffcult for but at the same time, I agree with it completely. 

2C. Closing the Case I like it. I was already planning to take that quote and use it and justify 

our stuff. Look, they are saying that we should try that. Happy to have that 

in there. 

Other participant’s response: 

[Longer-term intervention] helps with better case outcomes because if you 

stay involved longer and see whatever intervention you are putting in; you 

see it through. Then it doesn’t fall through the cracks and you get a reversal 

again for the referral again for the same thing. 
50 

Element Comment 

2C. Closing the Case I have to say I hear from lots of people that they would love to do longer case 

management of clients and that funding doesn’t allow that. So, guidance 

that says that, I don’t know if it should say keep cases open longer or 

say something along the lines of provide case management services, or 

something like that, but I actually think most people would agree that we 

would like to be involved longer. With the client’s consent of course. 

2C. Closing the Case While, this is a great idea. In reality our programs are incredibly shortstaffed. I second what she is sharing, we need funding and resources to be 

able to accomplish this. 

2C. Closing the Case I think the problem is the word “consider”. We all would consider that a great 

day I shouldn’t speak for everyone... but I think it is something we would like 

to do. So, we would consider it, we have to get legislation and funding to also 

consider it. So maybe is it a question of that word. 

2C. Closing the Case Maybe the word should be something that “should seek resources in 

order to....” 

2C. Closing the Case We need to consider how we are going to word that in that in a lot of 

jurisdictions we refer to more of that case management service. We don’t 

in adult protection at least in this state believe that we have the funds to 

keep things open indefnitely and according to best practice in 2012, most 

of the country was closing cases in 45 to 90 days but we realizes that there 

are cases that need to be open longer and we refer to AAA to provide case 

management services to those individuals. 

2C. Closing the Case The problem here is the fact that Counties no longer receive money for long 

term case management and intervention. 

2C. Closing the Case I am concerned a bit about balancing this with resources as well as with selfdetermination when clients have expressed unwillingness to work with APS. 

2C. Closing the Case Sometimes we have to recommend /direct local APS to NOT keep cases open 

as long as they may do, in order to better address incoming case. 

2C. Closing the Case Our county is not able to keep cases open unless circumstance truly warrant 

them. However, I’m happy to hear about Motivational Interviewing (MI) being 

effective for APS, we train MI in APS but there is often resistance from social 

workers because they feel these techniques may be more for therapists. 

2C. Closing the Case The only thing I would suggest in this area is if we are going to say consider 

keeping cases open longer, maybe talk about the baseline and what longer 

means. 

Is there a defnition for things considered longer term? We don’t have a 

defned time frame for having a case open. But we have cases that are 

shorter where we’re dealing with more presenting problems. And then we 

have other cases where the person is at a higher risk of future harm and 

involved for a longer time trying to resolve the root cause that is leading 

them to be at risk. Continued risk. Those cases can be open from anywhere 

from a few weeks to a few months. Depends. I didn’t know if there was some 

kind of thought behind what was meant by longer term. 

2C. Closing the Case Consider adding to the last sentence of that section or in another statement 

– “including referrals to other agencies” (this is related to relationship-based 

interventions) 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 51 

Domain 3. Receiving Reports of Maltreatment 

Element Comment 

3B. Screening, Prioritizing, and What is a “screened in report”? 

Assignment of Screened-in 

Reports 

Domain 4. Conducting the Investigation 

Element Comment 

Domain 4. Conducting the 

Investigation 

Investigation is inconsistent with a social service program when the older 

or vulnerable adult is the subject or when a primary support person in 

relationship with the older or vulnerable adult is the subject. Suggest 

assessment for neglect and/or fact-fnding assessment for abuse and 

exploitation; change domain title to “4. Conducting a Fact-Finding 

Assessment” 

4A. Determining If Maltreatment 

Has Occurred 

Add the following two items to the list of evidence typically gathered during 

investigations: 

• “Law enforcement history (e.g., 911 police calls or wellness checks) 

• Court records search history” 

4A. Determining If Maltreatment 

Has Occurred 

Revise 4A as follows: “the worker has been trained and is competent 

to investigate to conduct fact fnding on the particular set of circumstances 

described in the report (e.g., he/she has received training on working with 

nonverbal clients, with clients with intellectual disabilities, with clients 

with mental health issues, with residents of institutions, or with minority 

populations).” 

4A. Determining If Maltreatment 

Has Occurred 

I wonder if there is a way, and I don’t know if it is in the 5B section or another 

section, but I think that the term multidisciplinary team can be interpreted 

several different ways and I wonder if there is room for clarifcation about 

the types of multi-disciplinary teams. I mean obviously we are talking about 

a forensic center model here, but I think that at a basic level, it could be case 

consultation multi-disciplinary teams or more of a community awareness 

multi-disciplinary team. So, is there room within the guidelines to defne the 

different types? 

4A. Determining If Maltreatment 

Has Occurred 

How do you defne those terms, ‘Confrmed or unfounded’? 

Other participants’ responses to the question: 

• Yes, very important recommendation especially related to consistency. 

I’m thinking about implications for NAMRS and trying to ensure that 

we all mean the same thing when we indicate case fndings. 

• I agree, very important to gathering data. 

4A. Determining If Maltreatment 

Has Occurred 

Clear understanding for the fnding of “inconclusive” as well. 

4A. Determining If Maltreatment 

Has Occurred 

Put “screening” before “decision-making”, consistent with case fow; also, 

screening tools can be a type of decision-making tool so may want to be 

more precise in your language. 
52 

 

Element Comment 

4A. Determining If Maltreatment 

Has Occurred 

ACL identifes a series of issues that investigators should explore before 

deciding whether or not to notify the alleged victim of the initial visit, such 

as preservation of individual rights and evidence, maximum engagement 

potential with the client, and victim safety. We encourage ACL to add to this 

list the need for investigators to include other sources of information in 

investigations involving persons with dementia, as they may not be accurate 

or reliable reporters due to their cognitive impairment. 

4B. Conducting an APS Client 

Assessment 

Add the words: “with or without a Primary Caregiver” to the “Care needs” 

item in the domains listed (“Care needs with or without a Primary Caregiver”) 

4B. Conducting an APS Client 

Assessment 

On remote access, are there fndings we might quote to say something like 

video-teleconferencing is a viable intervention when in-person interactions 

aren’t feasible? My concern is that we might be read to say a future in which 

APS abandons face-to-face interactions as a prioritized approach. 

4B. Conducting an APS Client 

Assessment 

Assessment of APS clients may have signifcant legal ramifcations. 

Therefore, we support testing the use of technology (or other models) that 

enhance and facilitate APS client assessment by well-qualifed experts. 

4B. Conducting an APS Client 

Assessment 

We support several of the domains for a needs/risk assessment under the 

current guideline, such as functional ability and behavioral issues, but we 

respectfully request that ACL add “cognitive impairment” or “cognitive 

function” as a domain. 

4C. Investigations in Residential 

Care Facilities 

Consider adding a defnition of what a congregate setting is. 

4C. Investigations in Residential 

Care Facilities 

We recommend that the section address the timing of APS coordination with 

law enforcement and notifcation to the Ombudsman Program when APS 

investigates in a congregate care setting. I.e., Under the section heading of 

“Background”, second paragraph, we recommend inserting a new sentence 

at the end of the paragraph: “Before investigating a report of congregate 

care setting maltreatment, consultation with law enforcement about the 

timing of the APS investigation can ensure that an APS investigation does 

not compromise a law enforcement investigation that may be occurring 

or pending.” 

Under the section heading of “Background”, at the end of the third 

paragraph, add: “When APS receives an allegation of maltreatment of a 

resident of a congregate care setting, APS shall notify the LTCO of the APS 

investigation.” 

Domain 5. Service Planning and Service Implementation 

Element Comment 

5A. Voluntary Service 

Implementation 

Under the 5A Voluntary Intervention guidelines it should indicate 

“vulnerable adult mistreatment cases”. 

5A. Voluntary Service 

Implementation 

The frst sentence says intervention should be early in cases of “Elder 

mistreatment”. Suggest changing the word “elder” to “vulnerable adults”. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 53 

 

Element Comment 

5A. Voluntary Service 

Implementation 

Consider adding the guideline for those older adults and persons with 

disabilities that choose not to or do not have access to senior centers, 

congregate meal sites, etc. the use of telephone or computer socialization 

provided by the Without Walls Network which includes programs such as 

DOROT University Without Walls, Well Connected, Mather Lifeways, and 

Lifetime Connections Without Walls. There is research suggesting these 

interventions improve socialization and improve mental health outcomes. 

Additionally, consider adding Friendly Visitors programs for increased 

socialization, improved mental health outcomes. 

5A. Voluntary Service 

Implementation 

I have to say I hear from lots of people that they would love to do longer case 

management of clients and that funding doesn’t allow that. So, guidance 

that says that, I don’t know if it should say keep cases open longer or 

say something along the lines of provide case management services, or 

something like that, but I actually think most people would agree that we 

would like to be involved longer. With the client’s consent of course. 

5A. Voluntary Service 

Implementation 

While, this is a great idea. In reality our programs are incredibly shortstaffed. I second what she is sharing, we need funding and resources to be 

able to accomplish this. 

5A. Voluntary Service 

Implementation 

Timing of intervention needs to follow the pace of the client’s willingness 

to accept, especially in case seeking voluntary cooperation of the 

client. Sometimes need to engage client in order to get to the ultimate 

interventions sought. 

5A. Voluntary Service 

Implementation 

What comes up for me is the tension between the original role and intent of 

APS as a short-term crisis intervention program or service.... but what we are 

fnding in practice is that, even here in the guidelines, that there are clients 

that have a need for longer term interventions; but programs generally are not 

funded that way. I don’t know the answer; there is a system gap and should 

APS be the program that flls that gap? So, I am coming back to the tension 

between the original intent and role of APS vs. that unmet need and what APS 

programs are seeing clients really need in order to stabilize the situation. 

Other participants’ responses: 

• Absolutely, a great comment. 

• Agree. 

• Could it not be that as research and practice moves forward, the feld 

moves forward? We rethink APS? 

• I think keep in, if some can’t, as it sets a bar and maybe hope 

for possibility. 

5A. Voluntary Service 

Implementation 

I think that tension between aspirational and practical application is 

really important. And perhaps, just an idea, the guidelines could serve 

both purposes, if it gets called out a bit. Sort of ‘when available or where 

available’. So that workers are not put in the position of, well I am supposed 

to be doing this but I can’t because we don’t have the resources beyond the 

scope of what my program can provide. Where as in other locations maybe it 

is a resource that is available. It sort of gets called out a bit. I think there is 

value in doing that. If there is an APS worker that is looking to the guidelines, 

I think aspiration is critical to that. That is my opinion. I would love to hear 

other people’s thoughts. 

Other participants’ responses: 

• I like that idea of using the language of “when possible” or “when 

available.” 

• Yes, keep in - aspiration and repetition matter 
54 

 

Element Comment 

5A. Voluntary Service 

Implementation 

What about using least restrictive language? 

5A. Voluntary Service 

Implementation 

Wrap around services for victims of transnational predator scams should be 

fnancially supported, including long term case management, counseling, 

fnancial counseling, online/phone support groups for families and victims 

of chronic scams, creditor and legal help and other intervention services. 

Funding, perhaps similar to that supported in various HICAP programs, or 

through Area Agencies on Aging in each community could be funded to include 

both prevention and intervention services, as a referral source from APS. 

5A. Voluntary Service 

Implementation 

Add the words “or their designated representative’s” to the following 

sentence: “Service plans are monitored and changes can be made, with the 

client’s or their designated representative’s involvement, to facilitate services 

to address any identifed shortfalls or newly identifed needs and risks.” 

5B. Involuntary Service 

Implementation 

On p. 26 - I’m a bit concerned about how the outcome of safety through 

guardianship is represented. Could this perhaps be moderated by inserting 

the Burns fndings about client goal attainment into the lit review on 

coordination with other entities? 

5B. Involuntary Service 

Implementation 

I like you to extent it beyond the forensic center. There may be other models 

that would work and that have not been tested yet. There may be differences 

in large rural areas that don’t have that but may come up with something that 

works equally well in their setting and that kind of thing. I like broadening it 

to... such as forensic centers and other multi-disciplinary ways to address it. 

5B. Involuntary Service 

Implementation 

We don’t have forensic centers as such. We have enhanced multidisciplinary 

team. We have specialty forensic services available. Not necessarily 

embedded in forensic teams as such. We sometimes use those or APS uses 

them to determine whether guardianship is appropriate or not. Forensic 

accountant and geriatric psychiatrist that is available to those teams. 

(Indiscernible) those services are available to APS. 

Other participants’ responses: 

• It may be more common that folks do NOT have access to Forensic 

Centers so maybe include an alternative description for MDT’s as an 

example 

• Forensic Model must have expertise in Supported Decision Making 

and Guardianship alternatives in order to be an effective resource in 

making recommendations for guardianship 

5B. Involuntary Service 

Implementation 

I wonder if there is a way, and I don’t know if it is in the 5B section or another 

section, but I think that the term multidisciplinary team can be interpreted 

several different ways and I wonder if there is room for clarifcation about 

the types of multi-disciplinary teams. I mean obviously we are talking about 

a forensic center model here, but I think that at a basic level, it could be case 

consultation multi-disciplinary teams or more of a community awareness 

multi-disciplinary team. So, is there room within the guidelines to defne the 

different types? 

5B. Involuntary Service 

Implementation 

I have a question about something I don’t see a change in that I was 

wondering if it is under consideration. [RE] While the investigation may 

continue the client has the right not to participate in the investigation. So, in 

the 2016 version, in the back, it has stakeholder comments and one comment 

was that stakeholders requested the standard on involuntary interventions 

be very clear and some raised concerns with involuntary investigations. I am 

wondering if there are plans to address that further? 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 55 

 

Element Comment 

5B. Involuntary Service 

Implementation 

We fully support the concept of the proposed additions regarding use of a 

multidisciplinary approach to consider whether an APS client would beneft 

from having a guardian or conservator appointed if less restrictive options 

are insuffcient or unavailable. However, we take issue with the wording of 

the proposed additions. State courts determine if a guardian or conservator 

is needed, applying standards set forth in state law. APS, a forensic center, 

or a group of multidisciplinary experts may help determine whether APS 

or another entity with legal authority should petition a court to appoint a 

guardian or conservator, but they do not – and cannot – “make the diffcult 

determination as to whether a public guardian and guardianship is needed.” 

5B. Involuntary Service 

Implementation 

Is there any thought to referring to the American Bar Association-The 

PRACTICAL Tool? It aims to help lawyers identify and implement decisionmaking options for persons with disabilities that are less restrictive than 

guardianship. 

5C. Closing the Case Right before the call I looked over the document that was in the e mail 

blast about the webinars and updates and the recommendations about the 

possibility of monitoring cases longer term... I agree with it and I think it is 

a great idea. I just know from working with the APS programs over the years 

that it is a real challenge to work with clients for long periods of time when 

you are doing an investigation. That part made me a bit uneasy because I 

know that is going to be very diffcult for but at the same time, I agree with it 

completely. 

5C. Closing the Case Appreciate the person-centered approach of this addition to case closure 

guidance. 

5C. Closing the Case I think this is a great message... I am going to express my concern about it. Or 

potential concern with limited funding as everyone knows off the phone with 

no dedicated federal funding just APS outside of grants or getting creative 

with Medicaid funding or whatever else you use to fund your program, I think 

the goals of the client to be attained, if there are funding issues that might 

be a roadblock. 

5C. Closing the Case Looks good and aligns with previous discussion about what research is 

showing about longer-term interventions. 

5C. Closing the Case This [criteria for closing the case: “the goals of the client have been 

attained”] could be diffcult if the resource the client needs is not available 

Other participants’ responses: 

• Maybe specifc to each client and resources/services available? 

• Good point on service needed but not available 

• Goal attainment can’t be to meet goal that results in ongoing 

maltreatment by perp 

• Agree. Goal attainment is ideal, but not always realistic or possible. 

Particularly if we have to take legal action (i.e. guardianship referral) 

• I think it’s good to have. One of the choices and allows for autonomy 

of the client because we are voluntary 

5C. Closing the Case That might be challenging in this state. So, services here are very limited. 

And we are still trying to build our partnership with our area offce of aging, 

and they are willingness to accept our APS referrals. So that might be 

challenging and the question came up how long do we keep the case open? 

So that is just a comment. That might be challenging. 
56 

Element Comment 

5C. Closing the Case Thank you this is really great. The only thing I had and it is within the case 

closure. I felt it needed a bit of maybe I am over thinking it but I was thinking 

the defnition of case could be more clearly defned. There is a bit of overlap. 

My thinking is the case may be the hotline itself. And the interdictions 

providing during the investigation or it can be ongoing so we opened a 

protective services case. So, we are trying to utilize the same kind of reasons 

for closure. Tying it into NAMRS. That is my only comment. 

Domain 6. Training 

Element Comment 

6A. Caseworker and Supervisor 

Minimum Educational 

Requirements 

APS programs must have adequate procedures in place to screen potential 

candidates for employment for suitability. APS must ensure that their 

employment screening procedures are adequate and appropriately eliminate 

those candidates who do not meet the minimum qualifcations, or whose 

knowledge, skills, and abilities demonstrate a lack of capability to work with 

the subject population. Additionally, candidates who fail to cooperate with 

the screening process, provide false and/or incomplete information, or fail 

to share disqualifying information must be denied employment. Stringent 

prerequisites are necessary in this feld, and should not be relaxed to fll 

vacant positions. 

6B. Case Worker Initial and 

Ongoing Training 

6C. Supervisor Initial and Ongoing 

Training 

I like the section 6 changes 

6B. Case Worker Initial and 

Ongoing Training 

APS should ensure training is standardized to protect the integrity of 

program policies and procedures. We favor establishing clear defnitions 

for case fndings, noting that adequate training also be provided. Without a 

formal, documented training program in place, the program will only be as 

good as the trainer and their memory. With a standard training program in 

place, APS programs will be assured that all training will be consistent with 

the particular program’s policies. Moreover, standard training will guarantee 

that variability in clients’ experience will be minimized. 

6B. Case Worker Initial and 

Ongoing Training 

I would say if we could change determine to ‘screening... for capacity’ that 

would be helpful. 

Other participants’ responses: 

• Item #1g: change “the process for determining capacity” to “the 

process of screening for capacity” 

• Should probably be changed to process of screening for capacity 

• Instead of capacity (APS workers cannot determine capacity), 

consider using decision-making ability 

6B. Case Worker Initial and 

Ongoing Training 

1g, Orientation to the Job – We fully support the proposed addition of 

capacity to the list of topics about which new APS workers need orientation 

training. The wording of the addition is troubling, however, as it implies that 

new APS workers have the responsibility to “determine capacity.” We would 

recommend that (g) be revised to “the concept of capacity and how it is 

assessed” or “the different types of capacity and how they are assessed.” 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 57 

 

Element Comment 

6B. Case Worker Initial and 

Ongoing Training 

Item 3e: “Interviews with Older Adults and Caregivers” is currently not part 

of the developed NAPSA APS Core Competency curriculum offerings. Is this a 

recommendation that this course be developed? I am not clear. 

https://theacademy.sdsu.edu/programs/apswi/core-competency-areas/ 

6B. Case Worker Initial and 

Ongoing Training 

Item 4: “Advanced or Specialized Training” – Consider offering more 

examples of relevant advanced and specialized trainings offering knowledge, 

skills practice and replicable models on topics: advanced interviewing; 

advanced fnancial abuse topics; trauma-informed services; self-care and 

secondary trauma; emergency/disaster preparedness and response; working 

with multi-generational households; opioid abuse; older adult homelessness 

and poverty. These trainings should be open to all APS staff including 

Supervisors and Nurses. 

6B. Case Worker Initial and 

Ongoing Training 

Consider moving Certifcation Process language to create Guideline #5. It 

is not strictly related to Advanced or Specialized Training and includes core 

competency training, etc. 

6B. Case Worker Initial and 

Ongoing Training 

[Recommend adding guidance regarding the] development a national 

working group to develop policies, protocols and trainings on APS 

Emergency Preparedness and Response. Add training and related resources 

to Core Competency Training for APS Workers and Supervisors. 

6B. Case Worker Initial and 

Ongoing Training 

I wonder if in the guidelines, and this might be a confict of interest, but I 

feel like a lot of states that may have had turn over in adult protection in 

previous years, may not know about the core curriculum offered through 

San Diego State University, and I know that is kind of a best practice or gold 

standard, is there any way that can be mentioned in the guidelines? States 

are not trying to recreate this based on we should be trained in this or that 

or whatever... so they could be pointed in the direction of consistency for 

the certifcate program? Because I feel like at least in the west, we have had 

some turn over in representation and I know two people have been shocked 

that San Diego state has the core competencies that they would have access 

to and being new to adult protection, they were scrambling to try to invent it 

come something like that already exists. 

6B. Case Worker Initial and 

Ongoing Training 

Yes! Thank you for including virtual reality and sim. This is very aspirational 

and could be so impactful if/when resources are available. 

6B. Case Worker Initial and 

Ongoing Training 

Trainings including identifying older/vulnerable adult victims being exploited 

as money mules in transnational scams should be required. 

6B. Case Worker Initial and 

Ongoing Training 

Given the growth of the population affected by Alzheimer’s and related 

dementias in the coming years, we strongly encourage ACL to add 

“dementia” to the list of training core competencies. Dementia training 

curriculum should incorporate principles of person-centered dementia care 

including a thorough knowledge of the person and his or her abilities and 

needs, the advancement of optimal functioning and a high quality of life, 

and the use of problem-solving approaches to care. New and existing APS 

personnel should be trained adequately and appropriately to best address 

the needs of the individuals they serve. Training should be culturally 

competent, both for APS workers and clients 
58 

 

 

Element Comment 

6B. Case Worker Initial and 

Ongoing Training 

The Alzheimer’s Association and AIM have made training APS, law 

enforcement, and other frst responders a policy priority and we would 

welcome the opportunity to work with APS systems to develop, incorporate, 

or review their training. The Alzheimer’s Association offers the Approaching 

Alzheimer’s: First Responder Training Program, a free, online training that 

features high-quality content in an interactive format, developed by the 

Alzheimer’s Association with input from frst responders. We also offer 

curriculum review and our Alzheimer’s Association Dementia Care Practices 

Recommendations. 

6B. Case Worker Initial and 

Ongoing Training 

We recommend that APS systems establish clear defnitions for the terms 

“confrmed,” inconclusive,” and “unfounded,” and provide training to its 

employees on these defnitions, as well as how cases should be assigned to 

the different categories.” 

6B. Case Worker Initial and 

Ongoing Training 

3. Core competency training: Consider adding: “referrals to other agencies, 

state and federal laws, emergency relocation, and the ombudsman 

program.” 

6C. Supervisor Initial and Ongoing 

Training 

Much appreciated added guidance on safety!! 

6C. Supervisor Initial and Ongoing 

Training 

Consider bolstering this section, the availability and consistency of 

APS Supervisor training is variable across states and counties. Given 

the importance of APS Supervisors’ roles and responsibilities detailed 

throughout the rest of the Voluntary Guideline document, this section does 

not provide a suffcient training and professional development roadmap 

for states and counties. [See The APS Leadership Development Report] 

developed for the Adult Protective Services Workforce Innovations (APSWI), 

Academy for Professional Excellence, San Diego State University School of 

Social Work outlining a comprehensive APS Supervisor Training Plan. 

6C. Supervisor Initial and Ongoing 

Training 

I would like to offer the following documents to support and further 

strengthen area 6c [...]. In early 2019, APS Workforce Innovations (APSWI), 

a program of the Academy for Professional Excellence, San Diego State 

University School of Social Work, commissioned work on a leadership 

development project [...] The APS Leadership Development Report 

encompasses the frst phase or research portion of the project and includes 

an extensive examination of leadership theories, models, and literature. 

Program best practices and cross discipline leadership development 

programs are analyzed. It also includes focus group data from sessions 

conducted with statewide (California) and national leadership in the feld 

of aging and adult services examining the leadership training needs, 

current gaps, and suggested next steps in the process. The APS Leadership 

Development Framework encompasses the Leadership Development Plan 

for APS Supervisors and APS/Adult Service Managers. It leverages research 

and information from the Adult Protective Services Leadership Development 

Framework research report (Phase 1) as well as the National Adult Protective 

Services Association, Administration for Community Living, County Welfare 

Directors Association, California Department of Social Services, and 

California Regional Training Academies 

6C. Supervisor Initial and Ongoing 

Training 

NAPSA would like to further endorse the use of the documents created by the 

Academy to inform the area of Supervisor training. 
Appendix 3 | Updated National Voluntary Consensus Guidelines for State Adult Protective Service Systems 59 

Domain 7. APS Program Performance 

Element Comment 

7. APS Program Performance I know most states get rid of all their case fles from various programs 

between three and seven years. I am not sure there is a program out there 

that does ten years. Is there a way the NAMRS case management data for 

those that are collecting at that level, that NAMRS could hold that up for ten 

years? Just something to think about. 

7. APS Program Performance Why is the record retention period so long? We see this as a program liability! 

[“Programs may consider keeping records for approximately 10-15 years”] 

7. APS Program Performance Depends on what measures are used; we keep APS records for at least 6 

years after case closure. 

7. APS Program Performance I do have one question about the inclusion of word substantiated. Because 

we know in APS systems especially in contrast to CPS that we have more had 

a are inclusive (Indiscernible) perhaps to the lack of desire for involvement 

by the client can be pushed into sub Stan deviation or substantiation 

(Indiscernible) or where substantiation can be included. I wonder where may 

end up being overly restricted or way to broaden it to include in inclusive 

cases as well? 

Other participant’s response: 

• Agree with adding inconclusive in outcome evaluation 

7. APS Program Performance There seems to be an underlying assumption that if data is gathered it is 

communicated and used throughout the APS/Adult Services organization 

and/or conveyed in a way that is digestible and relevant to decision-makers, 

older adults/families, other providers, and the community as a whole. 

Consider adding to this section the importance of APS management and 

Adult Services Administrators to not only collect the data but be able to “tell 

a compelling story” with the data. Additionally, the importance of creating a 

“culture of inquiry and outcomes”, where data is collected in the service of 

helping clients as well as helping staff do their best work.