Vulnerable adult maltreatment reporting in Minnesota is governed by the Vulnerable Adults Act, Minn. Stat. § 626.557, with its definitions in § 626.5572. A mandated reporter who has reason to believe a vulnerable adult is being or has been maltreated must report immediately to the Minnesota Adult Abuse Reporting Center (MAARC), and the statute defines immediately as no longer than 24 hours from first knowledge.
Nearly everyone who works for a Minnesota care agency is a mandated reporter, and nearly everyone the agency serves is a vulnerable adult by definition. The agency also carries its own duties under § 245A.65: a written reporting policy, an internal review of every report, abuse prevention plans, and staff training within 72 hours of first direct contact.
This guide covers the definitions, the 24-hour report, internal reporting, training, investigation, retaliation protections, documentation, and the separate rule for children, as of September 2026.
Who is a vulnerable adult under § 626.5572
§ 626.5572, subd. 21 defines a vulnerable adult as a person 18 or older who meets any one of four tests:
| Category | Who it covers | Typical agency clients |
|---|---|---|
| Facility resident or inpatient | Residents and inpatients of hospitals, nursing homes, and other facilities | Community residential clients |
| Licensed program recipient | People receiving services from a program licensed under ch. 245A (with exceptions for outpatient substance use and mental health treatment) | 245D and adult day services clients |
| Home care or PCA recipient | People receiving services from a licensed home care provider, or personal care assistance under medical assistance | PCA and CFSS participants, home health clients |
| Functional test | People with a physical or mental infirmity that impairs their ability to care for themselves and an impaired ability to protect themselves from maltreatment | Anyone else, judged case by case |
The first three categories are automatic. A 245D client is a vulnerable adult because of the license, so staff never need to decide whether a client is vulnerable before reporting, only whether they have reason to believe maltreatment occurred.
Who is a mandated reporter
Subd. 16 defines a mandated reporter as a professional or professional's delegate while engaged in social services, law enforcement, education, the care of vulnerable adults, and other listed occupations. Subd. 6 defines a facility to include home care providers and any organization that provides or arranges personal care assistance, so a PCA or CFSS agency's workers are mandated reporters while working.
Direct support staff, PCAs and CFSS support workers, adult day staff, nurses, and program managers are all covered. Anyone else may report voluntarily (§ 626.557, subd. 3(b)), and a good-faith reporter is immune from civil and criminal liability under subd. 5.
What counts as maltreatment
Maltreatment is abuse, neglect, or financial exploitation (§ 626.5572, subd. 15). Each has a statutory definition:
| Term | Definition (§ 626.5572) | Examples staff see |
|---|---|---|
| Abuse (subd. 2) | Assault, criminal sexual conduct, and other listed crimes; conduct that is not an accident or therapeutic conduct and produces physical pain, injury, or emotional distress; any sexual contact between staff and a resident; forcing the person to perform services for another | Hitting, rough handling, threats, humiliation |
| Neglect (subd. 17) | Failure or omission by a caregiver to supply care or services, including food, clothing, shelter, health care, or supervision, that a reasonable person would deem essential | Missed medications, leaving a person unattended when the plan requires supervision, ignoring a medical need |
| Financial exploitation (subd. 9) | Unauthorized expenditure of funds entrusted to the caregiver, failure to use the person's resources for necessities, or obtaining money or property through undue influence, harassment, duress, deception, or fraud | Using a client's debit card, "borrowing" money, changing a beneficiary |
Accidents and therapeutic conduct are excluded from abuse, but the exclusions are for the investigator to apply, not the reporter. A staff person who is unsure whether a bruise was accidental has "reason to believe" and should report. Many of these events are also incidents under § 245D.02, subd. 11; the 245D incident reporting guide covers those parallel notifications.
How and when to report to MAARC
§ 626.557, subd. 3(a) says the mandated reporter "shall immediately report the information to the common entry point." Immediately is defined in § 626.5572, subd. 10 as "as soon as possible, but no longer than 24 hours from the time initial knowledge that the incident occurred has been received." The common entry point is MAARC, which under subd. 9 must be available 24 hours a day.
Per the DHS adult protection page, mandated reporters can call 844-880-1574 at any hour or use the web-based mandated reporter form, which returns a report reference number the reporter can save and print.
Under subd. 4(a), the report identifies the vulnerable adult, the caregiver, the nature and extent of the suspected maltreatment, any evidence of previous maltreatment, the reporter's name and address, and the time, date, and location. Report what you know; you do not need proof, and you should not investigate first.
| Clock | Deadline | Rule |
|---|---|---|
| Report to MAARC | Immediately, no longer than 24 hours from first knowledge | § 626.557, subd. 3; § 626.5572, subd. 10 |
| Facility tells an internal reporter whether it reported | Within two working days, in writing, protecting the reporter's identity | § 626.557, subd. 4a(b) |
| 245D license holder informs the case manager of the report | Within 24 hours, unless the case manager may be involved | § 245D.06, subd. 1(d) |
| MAARC or lead agency assigns the report | As soon as possible, no longer than two working days | § 626.557, subd. 9a |
| Internal review by the license holder | Within 30 calendar days of the report | § 245A.65, subd. 1 |
| Mandated reporter orientation for new staff | Within 72 hours of first direct contact, then annually | § 245A.65, subd. 3; § 245D.09, subd. 4 |
Internal reporting and the § 245A.65 policy
§ 245A.65, subd. 1 requires every DHS license holder, including 245D and adult day programs, to have a written maltreatment reporting policy and to orient clients and mandated reporters to it. The policy may offer internal reporting, naming a primary and secondary person to receive reports. DHS publishes a template, DHS-7634B, that must be posted in a prominent location.
Internal reporting has limits written into § 626.557, subd. 4a. The facility remains responsible for the immediate report to MAARC, must give the internal reporter written notice within two working days stating whether it reported, in a way that protects the reporter's identity, and cannot prohibit direct external reporting.
After any internal or external report, the license holder must complete an internal review within 30 calendar days that evaluates whether policies were followed, whether they were adequate, whether staff need more training, whether the event resembles past events with the same people or services, and whether corrective action is needed. The review must be documented, available to DHS on request, and followed by a corrective action plan.
§ 245A.65, subd. 2 also requires a program abuse prevention plan and an individual abuse prevention plan for each vulnerable adult, developed at initial service planning with the person's participation. The adult day services license guide shows where they sit in a center's licensing review.
Compliance note: the internal report is a convenience for staff, not a substitute for the MAARC report. If the designated person sits on a report for three days deciding whether it "counts," the agency has missed the 24-hour deadline. Set the internal rule as "forward to MAARC the same day unless the primary person documents why the definition is not met," and keep that decision in writing.
Training within 72 hours
§ 245A.65, subd. 3 requires each new mandated reporter to receive an orientation within 72 hours of first providing direct contact services to a vulnerable adult, and annually after that. It covers the reporting requirements and definitions in §§ 626.557 and 626.5572, the § 245A.65 duties, the program abuse prevention plan, and the internal reporting policy. For 245D programs, § 245D.09, subd. 4, clause (5) restates the rule; the 245D training and orientation guide explains how to document the date and trainer.
What happens after a report
MAARC screens the report and refers it within two working days to the lead investigative agency under § 626.5572, subd. 13: the Minnesota Department of Health (MDH) for hospitals, home care providers, nursing homes, and hospices; the Department of Human Services (DHS) for programs it licenses, including adult day care, 245D programs for people with disabilities, EIDBI agencies, and mental health programs; and the county social service agency for everything else, including vulnerable adults receiving personal care assistance under § 256B.0659.
The investigation ends in a finding: substantiated (a preponderance of the evidence shows maltreatment occurred), inconclusive, or false. A substantiated finding against an individual enters the records DHS reviews for background studies under § 245C.08 and can lead to disqualification; the background study guide covers reconsideration. A finding against the facility can lead to a licensing order.
Retaliation protections
§ 626.557, subd. 17 prohibits a facility from retaliating against a mandated reporter or a vulnerable adult because of a report, and creates a rebuttable presumption that any adverse action, such as discharge, demotion, or restriction of access, within 90 days of the report is retaliatory. The reporter's identity is confidential, and a mandated reporter who negligently or intentionally fails to report is liable for damages caused by the failure (subd. 7).
What to document
Keep a record of every report, internal or external, that shows: when and by whom staff first had reason to believe maltreatment occurred; the date, time, method, and reference number of the MAARC report; for internal reports, who received it, the decision, and the date of the two-working-day notice; the 24-hour notice to the case manager under § 245D.06, subd. 1(d); the 30-day internal review and corrective action plan; and the reporter's 72-hour orientation date.
Children: a different statute
Maltreatment of a person under 18 is reported under Minn. Stat. ch. 260E, not the Vulnerable Adults Act. § 260E.06 requires a mandated reporter to immediately report to the local welfare agency, police, the county sheriff, or tribal authorities, and § 260E.03, subd. 9 defines immediately as no longer than 24 hours. EIDBI agencies and 245D programs serving children use this path, so an agency serving both needs both procedures in its policy.
How Trustora helps
Trustora records a suspected maltreatment report as an incident with the § 245D.02, subd. 11 category and starts the clocks that follow: the MAARC report with its reference number, the 24-hour case manager notice, the two-working-day notice to an internal reporter, and the 30-calendar-day internal review with its five required findings and corrective action plan. Gap-day alerts fire before a step is late, and the 72-hour mandated reporter orientation is tracked per staff person from the date of first direct contact.
Reports are held in the service recipient record and an agency-wide log with role-based, field-level access, so a reporter's identity is visible only to designated reviewers. Every entry is written to an append-only, SHA-256-chained audit log, and the one-click DHS audit binder pulls the report history, reviews, and training records for any date range. See the platform overview for the incident and training workflow.