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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9/2/19  8:41 am
Commenter: Sean McGinnis, Hartwood Foundation, Inc.

Comments on Guidance Document requiring 90 days of operating funds

Hartwood Foundation, Inc. was founded in 1973 and currently provides housing and residential supports to more than one hundred fifty individuals with developmental disabilities in Fairfax and Henrico counties. At a time when many of the individuals we support are no longer able to work or attend day programs on a full-time basis and rely upon us for an increase in frequency and intensity of supports at home, additional unfunded mandates are unwelcome. 

As stated, the DBHDS guidance document is inconsistent with the language of the regulation. The guidance document states that, "...have sufficient funds for 90 days of operating expenses, whether in cash or a line of credit" whereas the regulation states, "...the amount needed shall be based on a working budget showing projected revenue and expenses". Without allowing for projected revenue, we consider this a would-be unfunded mandate and an untenable burden on many providers.

We strongly encourage a revision to the guidance document to allow for projected revenues to be included in the requirement and we thank you for your consideration.


CommentID: 75875