Karen: I wanted to
share the comments I made on the draft PAIMI PPR and the draft Advisory Council
Reports. I am concerned about us in
the field using this report until changes are made.
Interesting in modern
IT world…while I was making my edits/comments, I was seeing some comments
you were making this morning at
If you have questions,
I’ll be happy to explain any of my concerns. (I’ll forward the Advisory Council
Report edits in a separate email).
Dave
David
H. Zoellner, Managing Attorney
Protection
and Advocacy for People with Disabilities, Inc.
zoellner@protectionandadvocacy-sc.org
843
763-8571
800
743-2553
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-----Original
Message-----
From: Dave
Zoellner
Sent:
To:
'Summer.King@samhsa.hhs.gov'
Subject: Comments on PAIMI PPR 2007
draft
Ms. King: Attached are comments on
the proposed revision to the PAIMI PPR.
(I separately made comments on the PAC draft report). Thank you for offering this
opportunity. I am afraid that the
current form is not one that will be usable in the field and the
format/typographical errors/inconsistencies are not what should be expected in a
federal report form.
I have used “editing” mode and
comments as I reviewed the report.
General
observations:
1. There are many inconsistencies in format,
capitalization, and word choice from one section to
another.
2. The section on PAIMI grievances needs
special attention. It appears to
mix the two types of PAIMI grievances.
3. The word “rule” was used when
describing the PAIMI Regulations.
The much more common word choice is “Regulations” as indicated by the
fact they appear in the Code of Federal
Regulations.
4. At bottom of page three, a legal
citation has been misstated…reference should have been to USC but was typed as
CFR.
5. Section 1B 4 on Governing Board
did not use “people first” language.
As drafted, it asks about “mentally ill individuals” rather than
“individuals with mental illness”
6. Section 2 references “state” P&A
directors. For sensitivity to
Native American, DC, and territorial P&As, recommend delete “state” and merely refer to P&A directors.
7. Section 3….needs reformatting…I could
not see bottom half of letters in subsections
8. Section 4. The description of closed cases needs to
be made consistent throughout the subsections. Also the version used in the first one
is not clearly worded (other versions would be much preferable): Number of Complaints Cases Closed
only
9. Section 4 2D has an apparent
mistyping…..refers to NON-clients even though this is a CLIENT section. Seems to have been taken over from
non-client section of current PPR form without making corrections.
10. The
budget section, 9, desperately needs instructions/guidance added. In particular 9H is VERY unclear as to
what each line refers to and what total means. See detailed comments I have made
in text after discussion with our Director of Business Administration.
For information, I regularly participate as the legal
monitor for the federal PAIMI monitoring teams that visit P&As. I was part of the original group
trained for monitoring and have been on six visits over the last several
years.
If there are questions concerning any recommendations, I
may be contacted as indicated below.
Thank you for the opportunity to comment.
David H.
Zoellner, Managing Attorney
Protection and
Advocacy for People with Disabilities, Inc.
zoellner@protectionandadvocacy-sc.org
843
763-8571
800
743-2553
CONFIDENTIAL
LEGAL DOCUMENT---------------This email transmission may contain privileged and
confidential legal information, intended only for the use of the individual(s)
named herein. If the reader of this transmission is not the intended recipient,
you are hereby notified that any dissemination, distribution, or copying of this
communication or the information contained herein is strictly prohibited. If you
have received this communication in error, please notify the sender immediately
by voice at (800) 743-2553/(843) 763-8571 or by email at
zoellner@protectionandadvocacy-sc.org. Please delete
the original from any storage media and destroy any hard
copies.