From: Dave Zoellner [Zoellner@protectionandadvocacy-sc.org]
Sent: Wednesday, April 11, 2007 12:48 PM
To: Armstrong, Karen (SAMHSA/CMHS)
Subject: FW: Comments on PAIMI PPR 2007 draft
Attachments: Proposed Final Draft PAIMI PPR 2007 1-09-07.doc

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 10:05 ! I have no idea on whose server/computer the document you had “up” but I got to see the notes.

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.
1569 Sam Rittenberg Blvd.
Charleston SC 29407
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.

-----Original Message-----
From: Dave Zoellner
Sent: Wednesday, April 11, 2007 12:37 PM
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.
1569 Sam Rittenberg Blvd.
Charleston SC 29407
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.