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Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
Guidance Document Change: This is a new guidance document regarding the current requirement for 90 days of operating expenses per the Rules and Regulations for Licensing Providers by the Department of Behavioral Health and Developmental Services (12VAC35-105).
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8/13/19  10:44 am
Commenter: The Arc of Northern Virginia

Concerns with Proposed 90 Days of Operating Expenses Requirement

The Arc of Northern Virginia is a non-profit organization focused on protection of human and civil rights for people with developmental disabilities, as well as full, meaningful inclusion.  Though The Arc of Northern Virginia is not a traditional service provider, every single day we work closely with individuals with a range of developmental disabilities and their family members who are using and searching for service providers.  We do this through our Support Coordination program, our Public Guardianship program, and the many thousands of annual requests we get from people seeking information on all manner of subjects.

When people with disabilities and their loved ones ask about finding a provider, we are often fortunate enough to say that Northern Virginia has a large number of quality Medicaid Waiver providers.  However, we are also acutely aware that those providers often operate with narrow margins and must fundraise to keep their doors open.  We understand they struggle to meet the needs of people requesting their services while ensuring high quality supports.  Each day, our providers go above and beyond to ensure the people with developmental disabilities can access life changing supports, and with any less effort, the system would collapse.

Thus, we have serious concerns about new proposals for Medicaid Waiver Service Providers to have 90 days’ worth of reserve expenses on hand, without being able to take projected revenue into account.  This is a very significant financial burden, one that we fear many or most of our non-profit providers surviving on Medicaid dollars cannot meet.  This change does not seem to do anything greater to ensure providers are stable and healthy, but it does go a long way toward making operations challenging. 

Given the great challenges people already face in finding and maintaining a good provider, the thought of having the number of options plummet and/or be put under greater strain is deeply troublesome.  We have serious concerns that the result would be a lack of provider choice for people with disabilities, especially those who favor smaller organizations that would undoubtedly break under the strain of having to secure large amounts of credit and savings.

We hope the projected 90 day revenue will be taken into account in ensuring providers have adequate savings, and that DMAS and DBHDS will be doing all that is in their power to ensure providers are fully reimbursed in a timely manner.  That is a truly critical component to provider health.

Thank you for considering our remarks and for doing all that is possible to preserve provider choice for people with disabilities and their families.  That choice is a critical right and avenue toward ensuring people are able to find and utilize the most integrated services available.

CommentID: 75773