Close this search box.

The Voice of the

Commonwealth's Counties

Public Comment Period Now Open on Proposed Children’s Services Act Policy Regarding Submission of Reimbursement Requests; VACo Seeks County Feedback on Proposal

At its June 13 meeting, the State Executive Council (SEC) approved submission of a revised draft of SEC Policy 4.5.2 for a second period of public comment, which will close on August 16, 2024.

The proposed revisions to the policy, which may be found at this link, stem from discussions at the SEC at its December meeting regarding a set of appeals from several counties that had missed the September 30 deadline for submission of reimbursement requests.  Under current SEC policy, counties in this situation may submit a waiver request to the Office of Children’s Services, but the Executive Director does not have explicit authority to grant these requests, so waiver requests must be considered by the SEC.  The proposed revisions to the policy would allow the Executive Director to grant a waiver based on a determination of “good cause,” as defined in the policy.  A locality that disagrees with the Executive Director’s determination could appeal to the State Executive Council.

Based on feedback from members, VACo submitted public comments on an earlier draft of the proposed policy, which was circulated for an initial public comment period beginning in March 2024.  VACo’s suggestions were largely incorporated into the revised draft; however, SEC members raised several issues during the June 13 discussion on which VACo seeks further input from members.

Specifically, VACo is interested in situations in which providers do not submit invoices in a timely fashion.  The June 13 policy draft would list “[i]nstances where provider invoices to localities are delayed pending resolution of appeals of Medicaid denials of payment” as an example of “good cause” for which a waiver from the September 30 reimbursement deadline could be granted.  VACo seeks feedback from members as to whether this language adequately addresses situations of delayed receipt of invoices.

Member feedback will inform VACo’s public comments and may be sent to Katie Boyle (  Members may also submit comments directly to the Office of Children’s Services; public comment is being accepted until 5:00 p.m. on August 16, 2024, and may be submitted online via the Public Policy Comment Form (available at this link), via email to, or via U.S. Mail (1604 Santa Rosa Road, Suite 137, Richmond VA 23229).  If members submit comments directly to the Office of Children’s Services, VACo staff would greatly appreciate receiving a copy of your comments.

VACo Contact:  Katie Boyle

Share This
Recent Posts