Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
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3/16/18  7:27 pm
Commenter: Nicholas Krafft, Student, New York University School of Law

The Department should not change the current definition of group Home without a clear basis.
 

The amended definition of “group home” unnecessarily limits the types of communities that intellectually disabled adults could live in. In particular, it would foreclose a successful model involving live-in assistants who provide meaningful accompaniment in addition to necessary care. Even if the change were meritorious, the Department does not state a rationale for making the change, making it impossible for interested stakeholders to engage with such merits. Rather, it appears to be an arbitrary and capricious change. The Department should either preserve the current definition of “group home” or repropose in a way that provides proper notice and opportunity for comment.

CommentID: 63699