The guidance document related to “Requirement for 90 Days of Operating Expenses” is written in such a way that it will produce differences in interpretation across the state for licensing specialists responsible for licensing new sponsored homes or when renewing Sponsored Residential Providers. The matter of “90 Days of Resources” has been an issue we, as a provider of Sponsored Residential Services, have dealt with in the past with previous Directors of Licensing and we thought we had come to resolution. Some of the language within the document poses a risk to the future of Sponsored Residential Services.
Our recommended changes are as follows:
Paragraph 2: For all licensed services other than sponsored residential services, the line of credit should be in the provider’s or owner’s name.
This can be interpreted in different ways in relation to sponsored services.
Paragraph 3: The following forms of financial resources are acceptable to document proof of 90 days of operating expenses for all non-sponsored residential providers: 1) Personal or business savings account; 2) Personal or business checking account; 3) Home equity line of credit; 3) (typo from the memo) Bank line of credit; 4) Credit card with an available balance.
Paragraph 5: This means that the sponsors themselves, and not the sponsor’s employer, must have at all times the financial resources to cover their own mortgage or rent, utilities, dining expenses, etc., for 90 days independent of payments received for residents living in the home. In order to meet regulatory requirements, these resources must be kept in separate accounts from which personal daily operating expenses are withdrawn or from which payments received for residents living in the home are deposited.