I am submitting this comment as an employee of a VARR-accredited recovery residence. I support reasonable oversight that protects residents from unsafe housing, exploitation, fraud, and unethical practices. However, I have serious concerns about the administrative burden and unintended consequences of the proposed recovery residence regulations.
Recovery residences are not clinical treatment programs. Virginia law distinguishes recovery housing from clinical treatment, yet many of the proposed compliance, documentation, inspection, corrective-action, and reporting requirements move recovery residences toward a regulatory framework that resembles the infrastructure applied to licensed treatment providers, including ASAM 3.1 programs.
This creates a significant barrier for the recovery residence workforce. Recovery housing is built on the Social Model of Recovery, where lived experience, peer relationships, mutual accountability, community involvement, and recovery capital are central. Many exceptional recovery residence employees and house managers are people with lived experience—not clinicians or professional compliance administrators. Virginia should not regulate recovery housing in a way that unintentionally pushes these individuals out of the workforce.
The proposal also creates significant duplication of oversight. VARR-accredited residences already operate under established accreditation standards based on NARR standards. Adding another layer of state documentation, inspections, reporting, corrective-action processes, policies, and administrative requirements raises an important question: What additional resident protection does each duplicative requirement actually provide?
There are also potential consequences for access and affordability. Compliance costs money. Increased administrative staffing, training, documentation, legal and compliance expenses will ultimately be absorbed by providers, passed on to residents, or cause smaller recovery residences to close. At a time when Virginia needs safe recovery housing, regulations should not unintentionally reduce capacity or create barriers to entry for responsible providers.
I respectfully ask DBHDS to:
    •    Preserve a clear distinction between recovery housing and ASAM 3.1 clinical treatment.
    •    Avoid duplicating requirements already addressed through VARR/NARR accreditation.
    •    Evaluate the cumulative administrative and financial burden, not simply each requirement individually.
    •    Protect a recovery workforce in which lived experience remains an asset rather than an administrative disadvantage.
    •    Use risk-based oversight, focusing state resources on health and safety violations, exploitation, fraud, resident brokering, serious misconduct, and providers with demonstrated compliance problems.
    •    Consider whether additional requirements could unintentionally increase costs, close residences, and reduce access to safe recovery housing.
Virginia can protect residents without transforming recovery residences into treatment programs. I encourage DBHDS to develop regulations that provide meaningful accountability while preserving the Social Model of Recovery, the recovery workforce, and access to safe, affordable recovery housing