Could you please explain why a provider would be required to keep these funds in a separate account that is not currently being accessed by that provider?  It seems as though they are trying to make it so difficult for providers that the individuals they provide quality care and individualized services will be forced back into group homes and state run training centers. 

Our local, state, and federal governments should follow this practice of reserving a 90 Day Budget themselves to show us how it is done, then maybe service providers would not have to worry about being unpaid for three months.  This seems to be a burdensome and unnecessary wight to place on the backs of people with a heart of compassion who dedicate their lives to serve others less fortunate.