TO:                   Department of Medical Assistance Services

FROM:             John Eisenberg, Executive Director

RE:                   Comment on the Heightened Scrutiny Review Package for Vanguard Landing

Thank you for the opportunity to provide input on the Heightened Scrutiny Review Package for Vanguard Landing. I am offering this comment on behalf of the Virginia Board for People with Disabilities.

The Board fully supports each individual’s right to choose where they live, including Vanguard Landing and similar residential options. At the same time, we have significant concerns regarding Vanguard Landing’s compliance with the federal Home and Community-Based Services (HCBS) Settings Rule. This rule requires that residential settings for individuals with intellectual and developmental disabilities promote choice, autonomy, and meaningful community integration. Based on the information presented in the review package, the Board does not believe Vanguard Landing currently meets these standards.

Several findings raise particular concerns, including:

• Limited transportation options that restrict residents’ ability to access community activities
• Group-based scheduling of activities with few opportunities for individualized choice
• Constraints around meal times and limited opportunities for residents to independently prepare meals
• A lack of integrated, competitive employment opportunities for residents who wish to pursue work

To meet HCBS requirements, Vanguard Landing must demonstrate that residents are consistently offered meaningful, person-centered opportunities. This includes access to activities based on personal interests, reliable transportation, the ability to participate according to individualized schedules, and supports that enable residents to seek competitive, integrated employment if they choose. Fundamentally, individuals must have autonomy and control over their daily lives.

In closing, the Board respects Vanguard Landing’s mission and recognizes the alternative residential model it seeks to provide. However, based on the information available, we do not believe Vanguard Landing has demonstrated compliance with the HCBS Settings Rule. The model as currently implemented does not provide the level of person-centered planning or community integration required under federal standards.

Thank you again for the opportunity to comment.