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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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9/4/19  4:56 pm
Commenter: St. John's Community Services

90 Day Proposal

Good Afternoon,

The proposed requirement to have 90 days of operational reserves is simply an unbearable mandate, one that if implemented and enforced, will undoubtedly cause providers to seriously question whether this addition to the funding model makes providing services in VA sustainable.

The margins for IDD, Medicaid funded, related services are already razor thin, with providers  having to incur tremendous amounts of expenses, and provide services to vulnerable citizens, that they risk not getting entirely paid for, or paid for in a timely manner. Do to this funding model, the margins are simply not large enough to then require providers to have to stockpile 90 days worth of operational reserves.

This mandate will force providers to either stop providing certain services altogether, or make draconian cuts in staffing and service delivery, in order to create the capital needed to generate the reserve. It will force money and resources that should be used to attack the workforce crisis, and to bolster the quality of service delivery, to be set on the sideline.

While I applaud the effort to ensure financial sustainability for the sake of those we support, this is simply too great of a burden for providers to bear, and if implemented, will actually drive providers out of VA, and ultimately harm those who need their support the most!


Alan Thornton

President, St. John's Community Services


CommentID: 76011