The proposed requirement for creating a reserve account equal to 90 days operating expense or requiring a line of credit equal to 90 days of operating expenses will take millions of dollars out of Virginia's DD service delivery system. A service delivery system already experiencing severe fiscal challenges caused by inadequate Medicaid rates and a Direct Support Professional workforce crisis. There are many alternatives for monitoring and  ensuring the fiscal viability of organizations providing DD services. 

Implementing the guidance document with this interpretation omits the term "projected revenues" from the guidance document which is a key factor and results in a substantive  policy change. Substantive changes in a policy requires that it proceed through the traditional regulatory process and not through an interpretive guidance document.  The Office of Licensing needs to evaluate alternatives that will not produce  horrendous fiscal consequences and additional unfunded mandates.