On behalf of the VACBP, which includes more than 50 private-sector providers of community-based behavioral health services throughout Virginia with more than 160 locations, I write to express significant concern about the proposed interpretation of the “Requirement for 90 days of operating expenses.” Our concerns include the following:
In addition, we have questions that will be important to clarify before proceeding. This includes:
While the VACBP does not condone providers failing to meet their legal or financial obligations, we urge DBHDS to reconsider the interpretation of this regulation so that these significant concerns can be addressed. Further, the VACBP is more than willing to work with the Office of Licensing to help them to utilize existing tools or develop new ones if necessary to help ensure providers are operating in a fiscally responsible manner.
Thank you for your consideration of the VACBP’s perspective on this important issue.