Virginia's shortage of housing and services for people with developmental disabilities is real, but it cannot be the basis for finding Vanguard Landing compliant with federal HCBS standards, and on the current record it should not be found compliant. The purpose of those standards is to ensure people have genuine control over their daily lives, real opportunities to build relationships and work outside a disability-specific setting, and a home that is clearly distinct from whoever is providing their services — not simply a safe, pleasant place to live among peers. The review turned up serious gaps on exactly these points: transportation and outings that followed group schedules rather than individual preference, little evidence of regular interaction with the broader community, weak employment and engagement opportunities, and unresolved questions about residents who left the community and whether their home and their service provider were properly separated. Promises of future changes don't substitute for proof that residents' lives look different today, and approving the setting anyway would set a troubling precedent — treating a well-run congregate campus as equivalent to true community integration simply because better alternatives are scarce. The fix for that scarcity is building more individualized housing and supports statewide, not lowering the bar for what counts as community living.