Agencies | Governor
Virginia Regulatory Town Hall
Agency
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).
Previous Comment     Next Comment     Back to List of Comments
8/14/19  1:05 pm
Commenter: Nancy Hopkins-Garriss, Pleasant View, Inc.

Guidance related to 90 Days of Cash Reserves
 

Pleasant View, Inc. has provided support to individuals who have disabilities since 1971.  We are a non profit with a proven track record  of good service and support. 

We are concerned about the proposed Guidance Document "Requirements for 90 Days of Operating Expenses."  At PVI, we strongly believe that agencies should be fiscally responsible and meet all financial obligations.  Providers must operate as responsible businesses as well as support providers.   

We are concerned with the statement in the guidance document, "Therefore, both applicants of licensure and licensed providers must be able to provide proof, at any time when requested by a representative from the department, that they have sufficient funds for 90 days of operating expenses, whether in cash or a line of credit."   In the original regulation, the language includes  the words"projected income."   It is irresponsible for an organization, and especially a non-profit one, to maintain the level of funding necessary to meet the 90 day requirement without including the projected income.  Funds should be used for program improvement and enhancement.   It is also impossible to maintain that level of open ended line of credit with a lending institution.  

We agree with and support the comments from the VNPP.   As stated, we support the Department's efforts to ensure that all agencies providing services be responsible businesses.  We would also be supportive of inspection tools that provide information to the  Office of Licensing indicating agency fiscal responsibility.  

 

 

CommentID: 75778