Capacity and Competency in Decision Making
The
Alphabet Soup
of
Substitute and Supported
Decision Making
Backup Plan for Solos: 10-10-2017
Capacity and Competency
Defining “Capacity…”
Popular definitions hinge on an
individual’s ability or power.
Capacity is the ability or power to
Do something;
Feel something;
Understand something;
Or some combination of those abilities.
A remark on Competency vs.
Capacity
“Capacity” and “Competency” are similar
words, but they have very different
implications.
Capacity is the ability or power to make
decisions; understand; think; feel; do.
Competency is a legal determination
(finding) decided by a court.
For more on this, see:
https://www.iowaaging.gov/capacity-vs-competency
. Specifically applicable in Iowa
but with general applicability in Minnesota as well.
Shades of gray…
Capacity is not “black and white;” not
“either/or;” not “all or nothing;” not
“yes or no.”
Capacity looks different for different
people…
Capacity can even look different for the
same person at different times.
Can be thought of as a continuum.
Varying Degrees of Capacity
And, varying degrees of capacity are
required for various purposes:
Personal objectives;
Legal responsibilities;
Health and safety;
Employment goals and requirements;
Etc.
Varying Degrees of Capacity
Similarly, in the legal realm, the capacity
required to execute one type of
document differs from the capacity
required to execute another type.
Contractual capacity
Testamentary capacity
Capacity to execute a Health Care Directive
Substitute Decision Making
Acronyms Everywhere!
OFP
HRO
POA
HCD
POLST
DNR
DNI
DNH
AND
VA
RP
PR
TTEE
PRACTICAL
GUARD/CON
And on…and on…and
on…
Civil Legal Responses to Fin. Exp.
Civil suit (under variety of
circumstances)
Civil Protection Orders: OFP/HRO
http://www.mncourts.gov/mncourtsgov/media/fourth_distric
t/documents/OFP_v_HRO_Information_Sheet.pdf
Understand individual expectations,
particularly regarding contact with family
members or caregivers
Civil Legal Responses
Advance planning: estate planning;
incapacity planning; nominations of
fiduciaries and health care decision
makers; assignments of authority in
advance directives
Supported Decision Making (SDM)
http://supporteddecisionmaking.org/
Guardianship/Conservatorship action
What is a Fiduciary?
A Fiduciary is someone who manages
money or property for someone else.
A Fiduciary has four basic duties:
To act only in the best interest of the person he
or she is helping.
To manage the other person’s money or
property carefully.
To keep the other person’s money or property
separate from his or her own.
And to keep good records.
What is an “Advance Directive?”
An Advance Directive is a document
that:
Legally identifies another person to make a
decision for you whether or not (depending
upon the document) you’re able to make a
decision for yourself
And/or provides some instruction for that
other person regarding your wishes
Types of Advance Directives
Financial Directives (assignments of authority
creating Fiduciary relationship)
Trust
Power of Attorney (POA)
Statutory Short Form
General Durable
Other Financial Arrangements:
Rep Payee
VA Fiduciary
Nomination of Guardian (under some circumstances)
MA Authorized Representative
Types of Advance Directives
Health Care Directives
Minnesota Health Care Directive (HCD)
Living Will
Power of Attorney for Health Care
Nomination of Guardian
POLST
DNR/DNI/DNH
Why would a person want to
have an Advance Directive?
To assert her or his wishes in the event
she or he is not able to communicate
To provide clarity for family members or
friends
To authoritatively identify who will be
“in charge” or a decision-maker in
absence of principal
Power of Attorney
Legal document that gives permission
for another person (people) to conduct
financial business on your behalf.
You: “Principal”
Other(s) (Fiduciaries) identified as
“Attorneys In Fact”
Power of Attorney
Two types of Power of Attorney
documents in Minnesota:
General (or Common Law)
Statutory Short Form MN Stat. 523.23
Power of Attorney
Statutory Short Form Power of Attorney
Four Sections:
Powers
Durability
Gifting
Accounting
Power of Attorney
Properly Executed
Statutory Form
Signed or acknowledged in front of Notary
Initialed “Special Notice”
Note: specimen signatures and
acknowledgement signatures NOT
notarized
Note: no expiration date required
Termination of Durable Power
Durable Power of Attorney terminates
on the earliest to occur of:
The death of the principal
The expiration date specified in the
document
Or in the case of a spouse as an attorney in
fact; the commencement of separation,
dissolution or annulment proceedings
Revocation of Power of Attorney
An executed POA may be revoked by a
written revocation
signed by the principal
(or on behalf of principal by another, f.ex. a
guardian) and
acknowledged by a notary
public
.
Health Care Directive
Minnesota Statute 145C is the Minnesota
Health Care Directive
You can view a sample form there, or at the
Minnesota Attorney General’s Website:
http://www.ag.state.mn.us/pdf/consumer/
healtcaredir.pdf
Health Care Directive
Names a person (or people) to make a
health care decision on your behalf if you
are not able to make a decision
Unification of two prior documents:
Living Will
Power of Attorney for Healthcare
Health Care Directive
Best documents contain both elements
Nomination of substitute decision maker
Instructions regarding interventions
Opportunity to articulate preferences
with regard to intervention; but also
Organ donation
Burial or cremation
Other desires/preferences
Health Care Directive
Proper execution requires:
Signature in front of a notary
Or two disinterested witnesses
Either nomination of proxy, provision of
intervention instructions or both
Health Care Directive
Considerations:
Multiple decision makers – agreement?
Clarity of instructions – give conversational
guidance
Change in perspectives over time –
remember, this is a living document
Coordinate other documents with Health
Care Directive (DNR/DNI/DNH; POLST)
Health Care Directive
Revocation
:
A Health Care Directive may be revoked by:
Preparing a written statement saying it is
revoked or cancelled
Destroying it (remember multiple copies)
Telling at least two other people it has been
revoked
Writing a new Health Care Directive
Keep this distinction in mind:
While the authority of the Health Care
Agent is triggered by the incapacity of
the principal person under a Health
Care Directive; the Attorney In Fact is
empowered to act as soon as the Power
of Attorney document is executed (even
if the principal person retains capacity).
POLST
Provider Order for Life Sustaining
Treatment
Type of Health specific advance
directive
Completed by provider with patient
Ideal under specific circumstances –
terminal condition; end-of-life
What is a guardianship?
Relationship between an incapacitated person, the
“ward,” and a person who helps the ward, the
guardian
Guardian: a person who has qualified as a guardian
of a minor or incapacitated person pursuant to
appointment by a parent or spouse, or by the
court, and includes a limited, emergency, or
temporary substitute guardian but not a guardian
ad litem
Types:
‒
Guardian of a minor
‒
Guardian of an incapacitated person
What is a conservatorship?
Relationship between individual who cannot
manage his/her own financial affairs, the
“protected person,” and an individual helping
the protected person, the conservator.
Conservator: a person who is appointed by a
court to manage the estate of a protected
person, and includes a limited conservator
Types:
‒
Unlimited conservatorship
‒
Limited conservatorship
‒
Other Protective Order
MN Statute:
Uniform Guardianship and Protective
Proceedings Act: Minnesota Statutes §§
524.5-101 through 524.5-903
Bill of Rights for Wards or Protected
Persons: 524.5-120
Requirements in Imposition:
Must be reason to believe that the
person is incapacitated
Diagnosis which may indicate incapacity is
not enough
Must be evidence which supports the
belief, i.e. behavior which demonstrates
incapacity
Statutory Definition of
“Incapacity” in 524.5-102
“An individual who, for reasons other than
being a minor, is impaired to the extent of
lacking sufficient understanding or capacity
to make or communicate responsible
personal decisions, and who has
demonstrated deficits in behavior which
evidence an inability to meet personal
needs for medical care, nutrition, clothing,
shelter, or safety, even with appropriate
technological assistance.”
Risks In Imposing Guardianship
and/or Conservatorship
Imposition on Ward/Protected Person’s
civil rights and autonomy
Must be no “less restrictive
alternatives”
POA, HCD, trustee, other fiduciary
Supported Decision Making
Powers and Duties of Guardians and
Conservators
Guardians and Conservators subject to
control and direction of court at all time
Court shall grant only those powers
necessary to provide for demonstrated
needs of the ward or protected person
Court can terminate; called
“restoration”
What is a Representative Payee
or a VA Fidcuciary?
These are roles appointed by government
agencies to help manage income benefits
for another person.
Social Security, Railroad Retirement, and
the Office of Personnel Management
appoint “Representative Payees.”
The Department of Veterans Affairs
appoints “VA fiduciaries.”
What authority does the
Representative Payee or VA Fiduciary
have?
The Rep Payee or VA fiduciary manages
only the benefits of the appointing
agency.
The ability to control other matters such
as any other property, account, asset, or
health matter results out of legal
authority from some other source (a
POA, trust, or court appointment).
VA and Rep Payee Reporting
Requirements
Rep Payee annual reporting forms are
available form Social Security.
If a person is receiving SSI, additional reporting
is required.
VA fiduciaries must submit accountings
when asked for them – forms are available
from Veterans Affairs.
Agencies require notification regarding
changes of circumstance for the recipient
and for the fiduciary.
What is a Trustee?
A trustee is a person who makes
decisions about the money or property
in a trust.
There can be one trustee, or more than
one (co-trustees).
A “successor trustee” is a person who
acts when the initial trustee can no
longer make decisions.
What property does a trustee
manage?
A trustee has authority only over
property actually transferred into a
trust.
A trustee does not have legal authority
over property that exists outside the
trust.
To assert decisions over other property,
some other grant of authority is
required.
Other Roles within a Trust
The person who makes the trust may be
called the “settlor,” “grantor,” or
“trustor.”
The person who receives money or
property from the trust is called the
“beneficiary.” There may be one
beneficiary, or more than one (co-
beneficiaries).
Trustee roles and responsibilities
Roles and responsibilities of trustees
include basic fiduciary duties, as well as
many other specific responsibilities as
defined by the language of the trust
document itself.
You must review the trust document to
understand a trustees responsibilities.
What is Supported Decision
Making?
Supported Decision Making (SDM) is a
philosophy that acknowledges that
people are happier and safer when
exercising the most autonomy of which
they’re capable.
It’s an approach that maximizes
individual agency, and minimizes
external decision-making whenever
possible.
PRACTICAL Tool
P: Presume guardianship is not needed.
R: Reason – i.d. reasons for concern
A: Ask if concern is caused by temporary condition
C: Community – look at community resources and
accommodations
T: Team – ask the person whether she has already
created a team to help
I: Identify abilities – areas of strength and need in
decision-making
C: Challenges – identify any challenges posed
A: Appoint appropriate legal supporter or surrogate
L : Limit any necessary guardianship petition or order
- ABA Commission on Law and Aging
Civil Legal Responses or Tools
Agency involvement/Administrative
action:
CMS (Medicare/Medicaid)
Social Security (Rep Payee)
Veteran’s Administration (VA Fiduciary)
DHS and MDH (re. licensure matters,
among other reports)
Other civil legal responses?
Additional MN Statutes
Vulnerable Adult: Minn. Stat. 626.5572
Categorical and Functional Definitions
Inpatient at a Facility
Receives services at or from a facility
Receives services from a home care provider, or
person that acts as a personal care/medical
assistant
Possesses a physical, mental, or emotional
infirmity/dysfunction
Additional MN Statutes
Financial Exploitation: Minn. Stat.
609.2335
Breach of fiduciary duty - ie Power of Attorney
Use of property for something other than the
benefit of the vulnerable adult
Fails to use property for benefit for vulnerable
adult
Deprives vulnerable adult of financial resources
The Minnesota Adult Abuse
Reporting Center
Began receiving reports on July 1
st
, 2015.
Single toll-free number:
844-880-1574
Available 24 hours per day
Immediately notifies county agency (EPS); law
enforcement (crime); Med Ex, Ombudsman for MH
(suspicious death)
Refers directly to Lead Investigative Agency
Online reporting for mandatory reporters
Feeback to: dhs.adultprotection@state.mn.us
Consumer Financial Protection Guides:
Available free-of-charge from the CFPB website at
www.consumerfinance.gov/managing-someone-elses-money
Best Interest and Substituted
Judgement Standards
Best Interest Standard
(Fiduciaries)
Prudence: “. . . the fiduciary acts with the care,
skill, prudence, and diligence under the
circumstances then prevailing that a prudent
person acting in a like capacity and familiar with
such matters would use in the conduct of an
enterprise of a like character and with like aims, . .
.”
Individualization: “. . . based on the investment
objectives, risk tolerance, financial circumstances,
and needs of the investor, . . .”
Loyalty: “. . . without regard to the financial or
other interests of the Adviser, Financial Institution
or any Affiliate, Related Entity, or other party.”
Best Interest Standard
(Medical)
In general, what would be good for the
patient
What “Reasonable Person” would want
Generic (broad) interpretation
Can be employed when little or no
information exists about patient
Never maintained informative capacity (f.
ex. Children)
Substituted Judgment Standard
(Medical)
What patient herself would have wanted
Possibility for tailored, personalized,
precise interpretation
Can attempt to reconstruct autonomous
decision of patient, or implement earlier
decision (precedent autonomy)
Utility in scenarios in which a person
formerly maintained capacity
Additional Resources
National Center on Elder Abuse:
www.ncea.aoa.gov
National Clearinghouse on Abuse in Later Life:
www.ncall.us
Senior LinkAge:
www.mnaging.net
Office of Ombudsman for Long Term Care: www.mn.gov/dhs/people-
we-serve/seniors/services/ombudsman/
MN Help:
www.mnhelp.info
Center for Excellence in Supported Decision Making:
https://www.voamnwi.org/cesdm
National Center for the Prevention of Elder Abuse:
www.preventelderabuse.org
MN Association for Guardianship: www.minnesotaguardianship.org/
Consumer Financial Protection Bureau:
www.cfpb.gov
Minnesota Department of Commerce:
www.mn.gov/commerce
Minnesota Indian Women’s Resource Center:
www.miwrc.org
Questions/Discussion?
Marit Peterson, Program Director
Marit.Peterson@elderjusticemn.org
651-440-9300
Exploring the nuances of capacity and competency in decision making, this content delves into the definitions, differences, and implications of these terms. It highlights the varying degrees of capacity required for different purposes and provides insights into substitute decision making and the plethora of acronyms involved in this realm. Additionally, it discusses civil legal responses to financial exploitation and civil protection orders. The content emphasizes the complexity and importance of understanding individuals' abilities in decision making processes.
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Presentation Transcript
The Alphabet Soup of Substitute and Supported Decision Making Backup Plan for Solos: 10-10-2017
Defining Capacity Popular definitions hinge on an individual s ability or power. Capacity is the ability or power to Do something; Feel something; Understand something; Or some combination of those abilities.
A remark on Competency vs. Capacity Capacity and Competency are similar words, but they have very different implications. Capacity is the ability or power to make decisions; understand; think; feel; do. Competency is a legal determination (finding) decided by a court. For more on this, see: https://www.iowaaging.gov/capacity-vs-competency. Specifically applicable in Iowa but with general applicability in Minnesota as well.
Shades of gray Capacity is not black and white; not either/or; not all or nothing; not yes or no. Capacity looks different for different people Capacity can even look different for the same person at different times. Can be thought of as a continuum.
Varying Degrees of Capacity And, varying degrees of capacity are required for various purposes: Personal objectives; Legal responsibilities; Health and safety; Employment goals and requirements; Etc.
Varying Degrees of Capacity Similarly, in the legal realm, the capacity required to execute one type of document differs from the capacity required to execute another type. Contractual capacity Testamentary capacity Capacity to execute a Health Care Directive
Acronyms Everywhere! OFP AND HRO VA POA RP HCD PR POLST TTEE DNR PRACTICAL DNI GUARD/CON DNH And on and on and on
Civil Legal Responses to Fin. Exp. Civil suit (under variety of circumstances) Civil Protection Orders: OFP/HRO http://www.mncourts.gov/mncourtsgov/media/fourth_distric t/documents/OFP_v_HRO_Information_Sheet.pdf Understand individual expectations, particularly regarding contact with family members or caregivers
Civil Legal Responses Advance planning: estate planning; incapacity planning; nominations of fiduciaries and health care decision makers; assignments of authority in advance directives Supported Decision Making (SDM) http://supporteddecisionmaking.org/ Guardianship/Conservatorship action
What is a Fiduciary? A Fiduciary is someone who manages money or property for someone else. A Fiduciary has four basic duties: To act only in the best interest of the person he or she is helping. To manage the other person s money or property carefully. To keep the other person s money or property separate from his or her own. And to keep good records.
What is an Advance Directive? An Advance Directive is a document that: Legally identifies another person to make a decision for you whether or not (depending upon the document) you re able to make a decision for yourself And/or provides some instruction for that other person regarding your wishes
Types of Advance Directives Financial Directives (assignments of authority creating Fiduciary relationship) Trust Power of Attorney (POA) Statutory Short Form General Durable Other Financial Arrangements: Rep Payee VA Fiduciary Nomination of Guardian (under some circumstances) MA Authorized Representative
Types of Advance Directives Health Care Directives Minnesota Health Care Directive (HCD) Living Will Power of Attorney for Health Care Nomination of Guardian POLST DNR/DNI/DNH
Why would a person want to have an Advance Directive? To assert her or his wishes in the event she or he is not able to communicate To provide clarity for family members or friends To authoritatively identify who will be in charge or a decision-maker in absence of principal
Power of Attorney Legal document that gives permission for another person (people) to conduct financial business on your behalf. You: Principal Other(s) (Fiduciaries) identified as Attorneys In Fact
Power of Attorney Two types of Power of Attorney documents in Minnesota: General (or Common Law) Statutory Short Form MN Stat. 523.23
Power of Attorney Statutory Short Form Power of Attorney Four Sections: Powers Durability Gifting Accounting
Power of Attorney Properly Executed Statutory Form Signed or acknowledged in front of Notary Initialed Special Notice Note: specimen signatures and acknowledgement signatures NOT notarized Note: no expiration date required
Termination of Durable Power Durable Power of Attorney terminates on the earliest to occur of: The death of the principal The expiration date specified in the document Or in the case of a spouse as an attorney in fact; the commencement of separation, dissolution or annulment proceedings
Revocation of Power of Attorney An executed POA may be revoked by a written revocation signed by the principal (or on behalf of principal by another, f.ex. a guardian) and acknowledged by a notary public.
Health Care Directive Minnesota Statute 145C is the Minnesota Health Care Directive You can view a sample form there, or at the Minnesota Attorney General s Website: http://www.ag.state.mn.us/pdf/consumer/ healtcaredir.pdf
Health Care Directive Names a person (or people) to make a health care decision on your behalf if you are not able to make a decision Unification of two prior documents: Living Will Power of Attorney for Healthcare
Health Care Directive Best documents contain both elements Nomination of substitute decision maker Instructions regarding interventions Opportunity to articulate preferences with regard to intervention; but also Organ donation Burial or cremation Other desires/preferences
Health Care Directive Proper execution requires: Signature in front of a notary Or two disinterested witnesses Either nomination of proxy, provision of intervention instructions or both
Health Care Directive Considerations: Multiple decision makers agreement? Clarity of instructions give conversational guidance Change in perspectives over time remember, this is a living document Coordinate other documents with Health Care Directive (DNR/DNI/DNH; POLST)
Health Care Directive Revocation: A Health Care Directive may be revoked by: Preparing a written statement saying it is revoked or cancelled Destroying it (remember multiple copies) Telling at least two other people it has been revoked Writing a new Health Care Directive
Keep this distinction in mind: While the authority of the Health Care Agent is triggered by the incapacity of the principal person under a Health Care Directive; the Attorney In Fact is empowered to act as soon as the Power of Attorney document is executed (even if the principal person retains capacity).
POLST Provider Order for Life Sustaining Treatment Type of Health specific advance directive Completed by provider with patient Ideal under specific circumstances terminal condition; end-of-life
What is a guardianship? Relationship between an incapacitated person, the ward, and a person who helps the ward, the guardian Guardian: a person who has qualified as a guardian of a minor or incapacitated person pursuant to appointment by a parent or spouse, or by the court, and includes a limited, emergency, or temporary substitute guardian but not a guardian ad litem Types: Guardian of a minor Guardian of an incapacitated person
What is a conservatorship? Relationship between individual who cannot manage his/her own financial affairs, the protected person, and an individual helping the protected person, the conservator. Conservator: a person who is appointed by a court to manage the estate of a protected person, and includes a limited conservator Types: Unlimited conservatorship Limited conservatorship Other Protective Order
MN Statute: Uniform Guardianship and Protective Proceedings Act: Minnesota Statutes 524.5-101 through 524.5-903 Bill of Rights for Wards or Protected Persons: 524.5-120
Requirements in Imposition: Must be reason to believe that the person is incapacitated Diagnosis which may indicate incapacity is not enough Must be evidence which supports the belief, i.e. behavior which demonstrates incapacity
Statutory Definition of Incapacity in 524.5-102 An individual who, for reasons other than being a minor, is impaired to the extent of lacking sufficient understanding or capacity to make or communicate responsible personal decisions, and who has demonstrated deficits in behavior which evidence an inability to meet personal needs for medical care, nutrition, clothing, shelter, or safety, even with appropriate technological assistance.
Risks In Imposing Guardianship and/or Conservatorship Imposition on Ward/Protected Person s civil rights and autonomy Must be no less restrictive alternatives POA, HCD, trustee, other fiduciary Supported Decision Making
Powers and Duties of Guardians and Conservators Guardians and Conservators subject to control and direction of court at all time Court shall grant only those powers necessary to provide for demonstrated needs of the ward or protected person Court can terminate; called restoration
What is a Representative Payee or a VA Fidcuciary? These are roles appointed by government agencies to help manage income benefits for another person. Social Security, Railroad Retirement, and the Office of Personnel Management appoint Representative Payees. The Department of Veterans Affairs appoints VA fiduciaries.
What authority does the Representative Payee or VA Fiduciary have? The Rep Payee or VA fiduciary manages only the benefits of the appointing agency. The ability to control other matters such as any other property, account, asset, or health matter results out of legal authority from some other source (a POA, trust, or court appointment).
VA and Rep Payee Reporting Requirements Rep Payee annual reporting forms are available form Social Security. If a person is receiving SSI, additional reporting is required. VA fiduciaries must submit accountings when asked for them forms are available from Veterans Affairs. Agencies require notification regarding changes of circumstance for the recipient and for the fiduciary.
What is a Trustee? A trustee is a person who makes decisions about the money or property in a trust. There can be one trustee, or more than one (co-trustees). A successor trustee is a person who acts when the initial trustee can no longer make decisions.
What property does a trustee manage? A trustee has authority only over property actually transferred into a trust. A trustee does not have legal authority over property that exists outside the trust. To assert decisions over other property, some other grant of authority is required.
Other Roles within a Trust The person who makes the trust may be called the settlor, grantor, or trustor. The person who receives money or property from the trust is called the beneficiary. There may be one beneficiary, or more than one (co- beneficiaries).
Trustee roles and responsibilities Roles and responsibilities of trustees include basic fiduciary duties, as well as many other specific responsibilities as defined by the language of the trust document itself. You must review the trust document to understand a trustees responsibilities.
What is Supported Decision Making? Supported Decision Making (SDM) is a philosophy that acknowledges that people are happier and safer when exercising the most autonomy of which they re capable. It s an approach that maximizes individual agency, and minimizes external decision-making whenever possible.
PRACTICAL Tool P: Presume guardianship is not needed. R: Reason i.d. reasons for concern A: Ask if concern is caused by temporary condition C: Community look at community resources and accommodations T: Team ask the person whether she has already created a team to help I: Identify abilities areas of strength and need in decision-making C: Challenges identify any challenges posed A: Appoint appropriate legal supporter or surrogate L : Limit any necessary guardianship petition or order - ABA Commission on Law and Aging
Civil Legal Responses or Tools Agency involvement/Administrative action: CMS (Medicare/Medicaid) Social Security (Rep Payee) Veteran s Administration (VA Fiduciary) DHS and MDH (re. licensure matters, among other reports) Other civil legal responses?
Additional MN Statutes Vulnerable Adult: Minn. Stat. 626.5572 Categorical and Functional Definitions Inpatient at a Facility Receives services at or from a facility Receives services from a home care provider, or person that acts as a personal care/medical assistant Possesses a physical, mental, or emotional infirmity/dysfunction
Additional MN Statutes Financial Exploitation: Minn. Stat. 609.2335 Breach of fiduciary duty - ie Power of Attorney Use of property for something other than the benefit of the vulnerable adult Fails to use property for benefit for vulnerable adult Deprives vulnerable adult of financial resources
The Minnesota Adult Abuse Reporting Center Began receiving reports on July 1st, 2015. Single toll-free number: 844-880-1574 Available 24 hours per day Immediately notifies county agency (EPS); law enforcement (crime); Med Ex, Ombudsman for MH (suspicious death) Refers directly to Lead Investigative Agency Online reporting for mandatory reporters Feeback to: dhs.adultprotection@state.mn.us
