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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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8/30/19  7:18 pm
Commenter: Sylisa Lambert-Woodard, Pres/CEO Pathway Homes, Inc.

90-day reserve requirement

Pathway Homes, Inc., is a private, not for profit agency providing services to individuals with serious mental illness, substance use disorders and intellectual and developmental disabilities.  We primarily receive funding on a reimbursement, fee for service basis. Although we have secured a line of credit, it is generally very difficult to secure a line of credit without utilizing restricted assets of the organization as collateral and security. The on- hand cash reserves, with the available line of credit, are at times insufficient to meet the 90-day reserve requirement as stated in the proposed regulation. 

As a DBHDS provider, with an extensive asset portfolio of homes, required reserves are maintained for the care, maintenance and improvements needed to these properties. The proposed regulation would not include these cash reserves in the requirement, yet they are essential to maintaining our asset portfolio to provide the necessary housing to our vulnerable consumers. 

Additionally, we also share the same concern that it is very difficult to interpret audited and unaudited financial statements due the presentation in conformance with the Government Auditing Standards, Uniform Administrative Requirements.  The Notes to the financial statements, provide information to supplement the Statement of Activities, however they do not provide information for which programs funded are licensed by DBHDS.

CommentID: 75849