Karen: Here are my
comments on the PAIMI Advisory Council Report form that I sent to Ms. King
yesterday.
You should have a
separate e-mail about the PAIMI PPR form itself.
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: Review and comments on PAIMI ACR
Section of PPR
Ms. King: Attached are comments on
the proposed revision to the PAIMI Advisory Council
Report.
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. There is a date of 12-30 for
reporting vacancies on the PAIMI council. As the reporting year otherwise
ends 9-30, the 12-30 date is strange. If a P&A wanted to efficiently
sent their report in October or November they wouldn’t know the number of
vacancies as of 12-30.
This would imply all reports HAD to be done on 12-30 or after! In some years, 12-30 could be a Saturday
or Sunday.
5. Unlike the prior reporting forms, this
one would have P&As report vacancies on the Council BY ETHNIC GROUP. That would improperly imply that
specific seats are reserved for particular ethnic groups. The Regulation requires only that
”Continuing efforts shall be made to include members of racial and ethnic
minority groups….” There is no
specific number required as would warrant showing “vacancies” on a line-by-line
basis.
For information, I regularly
participate as the legal monitor for the federal 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.