I am Michael Smith, Rear Admiral US Navy (Ret.) Chairman of MVLE Board of Directors Rear Admiral, US Navy (Ret.). MVLE's Board of Directors and myself are very concerned and believe that Virginia Department of Behavioral Health and
Developmental Services Office of Licensure Guidance Document requiring all DBHDS licensed service providers to have "90 days of operating expenses," is unreasonable and counter-productive to sustaining and growing Virginia's intellectual and developmental disability (IDD) service system capacity.
MVLE is a non-profit that for 45-years has served individuals with intellectual and developmental disabilities in the community. We are licensed, CARF accredited, a member of the National Capital Area United Way, Ability One vendor, Virginia DMAS provider and contract service provider for employment and day support services to DARS and CSBs in Northern Virginia. Annually MVLE supports more than 400 individuals.
DBHDS Office of Licensure's intention to require all licensed service providers to have '90 days of operating expenses" is excessive and if implemented will reduce resources needed to maintain much less create programs and services.
Placing aside a dedicated 90-day operating expense reserve, is the equivalent of creating an escrow account for the Department's sole use. To create accounts as required would reduce existing services to individuals already being served.
This requirement would add to the existing problems with the IDD service delivery system i.e. low reimbursement Medicaid rates and the DSP workforce crisis of recruitment and retention.
There are many ways the Department can monitor the fiscal viability of an organization other than requiring a reserve of 90 days of operating expenses or a line of credit equivalent to 90 days of operating expenses. Here are a few methods that don't impose the equivalent of an unusable escrow —holding tank account to set aside 90 days operating expenses:
Please reconsider the drastic implications that the 90-day fiscal reserve policy interpretation and implementation would have on Virginia's service delivery system. Given the outcomes of implementing this policy, does the proposed regulatory interpretation reflect good public policy implementation that supports services to the IDD Community? Please consider the key factors and assumptions used to develop this requirement. Several alternatives exist that can provide creditable, clear and neutral fiscal assessments of an organization's fiscal health and sustainability without removing millions in service dollars that are needed to grow Virginia's IDD service system capacity.
Respectfully
Michael Smith, Rear Admiral US Navy (Ret.)
Chairman of MVLE Board of Directors