Agencies | Governor
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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8/30/19  4:58 pm
Commenter: Clif MacDonald, Good Life Corporation

Guidance re Financial Reserves

Good Life Corporation has been providing supports to people with intellectual disability since 1989.

GLC supports the statement submitted by the Virginia Network of Private Providers and agrees that the language of the regulation including, “The amount needed shall be based on a working budget showing projected revenue and expenses.”  is of utmost importance and is overlooked in the Guidance Document proposed by the DBHDS Office of Licensing.

Both non-profit and for-profit providers must balance the responsibilities of operating a viable business and providing services to people.  Not considering projected revenue in establishing surplus reserves is contrary to common business practice.  Financial institutions take projected revenue into consideration, in addition to surplus reserves, when establishing the strength of a business.  There must be a balance between meeting the needs of the business, or the operational side of providing services, and providing services.  Disregarding a provider’s projected revenue shifts the balance, unnecessary taking funds from benefiting the people the provider supports.

Good Life Corporation agrees with the comments from VNPP and hopes collaboration can occur with the Office of Licensing to develop tools to use when conducting inspections which will identify problem areas without causing providers to cease operations.

CommentID: 75848