Thank you for the opportunity to comment.

I strongly support the direction of proposed § 12VAC35-260-170 because it recognizes that recovery is not one size fits all. Some people choose complete abstinence. Others may use legally authorized medical treatment while still living stable, productive lives in recovery. Both deserve safe housing and meaningful options.

My biggest concern is whether that choice will actually exist in practice.

Section 170 appears to allow operators to either prohibit marijuana entirely or permit medical cannabis under strict protocols for residents with valid Virginia certifications. However, other sections still appear to require accreditation through VARR or Oxford House before DBHDS certification. 

If a residence follows every DBHDS requirement under the medical cannabis pathway but a credentialing entity refuses to accredit it solely because of that choice, then Option 2 is not truly an option.

I respectfully ask DBHDS to make sure the final regulations protect both pathways in practice, provide a meaningful independent certification route, and ensure operators are not penalized for third party delays or private policies that conflict with options expressly allowed by the Commonwealth.

This is bigger than cannabis. It is about preserving choice, dignity, and multiple pathways to recovery while still maintaining strong safety and accountability standards.

The people living in recovery residences deserve protection, but they also deserve options.

Kayla McCue
Greenhouse RVA

P.S. Greenhouse RVA has been operating since 2021 and has years of direct experience operating a structured, medical-cannabis-inclusive recovery residence. We already have policies, safeguards, monitoring practices, and real-world experience addressing many of the questions now being considered. To date, no one involved in developing these regulations has reached out to us to ask what has worked, what challenges we have encountered, or what safeguards we have learned are necessary. As this framework continues to develop, I respectfully encourage the workgroup to include operators who are already doing this work. We would gladly share our experience, policies, challenges, and ideas if they could help create a safer and more workable system for residents across Virginia.