My son is alive today because of an Oxford House. I support certification, but as drafted, several rules cannot be followed by a self-governed house with no employees. I ask to make three changes.

1. Do not require staff that self-governed houses do not have. Section 40 correctly says an Oxford House is "self-governed and unstaffed," but other sections assume staff. Section 140 requires a "staff member" to handle complaints and contact residents within 24 hours; section 160 requires a "staff person" as community liaison, and section 190(D) requires a "staff member" to answer handbook questions. An Oxford House has no employees, so it cannot comply. Please allow these duties to be carried out by the house's elected officers or members, or state that houses operating under Oxford House, Inc. standards meet them.

2.  Say clearly whether Oxford House members are the "operator." Section 10 defines the operator as "the owner of a recovery residence or his designated agent." Sections 80, 140, 150, 160, and 200 place duties on the operator, and under section 40 anyone who operates a residence without certification faces a Class 1 misdemeanor, so who counts as the operator matters. Oxford House residents rent the home from a landlord. They do not own it or appoint an agent. Please state who the operator of a self-governed house is, and make clear that individual residents are not personally responsible for duties that belong to an owner.

3.Do not assume every recovery home is a commercial business. Section 50(B)(1)(l) requires proof of business insurance, including general liability, and section 150 requires every operator to show State Corporation Commission registration. An Oxford House is an unincorporated association of residents who split household expenses. It is not a business and has no reason to register as one. Section 50(B)(2) accepts an Oxford House charter in place of the application, which helps, but section 150 stands alone and the draft does not say whether a charter satisfies the insurance requirement. Please exempt unincorporated associations from SCC registration and require only insurance suited to a shared household.

These changes protect residents without ending a model that has worked for over fifty years.

Thank you for considering them.

Leslee Parsons