Better Men of Virginia, Inc. is a Virginia nonprofit corporation preparing its first recovery residence, an eight-bed monitored (NARR Level II) house in Petersburg for men in recovery, including men returning from incarceration. Our accreditation application is with the Virginia Association of Recovery Residences, and our full policy set is written to the credentialing standard. We comment as a new operator building to this chapter before opening, not as one asking to be excused from it.

We support the draft. Minimum standards, a real complaint process, the prohibition on resident brokering, and clear grounds for decertification protect residents and protect honest operators from being undercut by houses that sell beds and call it recovery. The eight comments below are offered to make the chapter easier to comply with, and easier to enforce.

1. Say what "submitted to the credentialing entity" means for conditional certification

Conditional certification turns on an applicant's policies being with a credentialing entity. We ask the department to state the proof it will accept, such as a dated written acknowledgment from the credentialing entity, and to commit to a decision timeframe on a conditional application. New operators sign leases, bind insurance, and raise capital against that date. A published timeframe costs the department little and prevents an empty, paid-for house from sitting closed.

2. Make the local zoning requirement workable

Certification requires local zoning compliance, but no Virginia statute classifies a certified recovery residence as a single-family use, and § 15.2-2291 reaches licensed group homes rather than certified residences. Localities answer this differently. We ask the department to state that a written zoning determination from the locality, or documentation of a pending reasonable-accommodation request under fair housing law, satisfies the requirement at application, with final compliance confirmed before certification. Without that, a compliant operator can be stalled indefinitely by a locality that simply does not answer.

3. Tie the 50-square-foot bedroom standard to the building code

The draft sets no less than 50 square feet of floor space per resident. We ask the department to say how the space is measured, whether closets and required means of egress count, and how the standard reads against the Uniform Statewide Building Code, including § 36-105.4 and egress for basement bedrooms. Operators measure rooms before signing leases. One sentence here prevents a house from being furnished to one standard and inspected against another.

4. Put an outer limit on "timely and fair review" of complaints

We support the 24-hour response for abuse allegations and the rule that no agreement may restrict a resident's right to complain. We ask the department to add a plain outer limit for all other complaints, such as a written response within ten business days, and to publish a model complaint form and a resident-facing poster. Small operators will comply with a form the department writes far more consistently than with a form each of us drafts alone.

5. Publish the data-reporting fields before January 1, 2027, and keep them de-identified

Reporting obligations take effect January 1, 2027. We ask the department to publish the fields, format, and cadence at least 90 days ahead, and to require counts rather than resident-level records wherever counts will do. Recovery residences serve people whose treatment records are protected under 42 CFR Part 2, and many residents arrive under court or probation supervision. A reporting scheme built on counts protects residents and keeps small operators out of the business of building record systems they cannot secure.

6. Say plainly how state bed funding relates to conditional certification

Operators are told that state-funded beds require accreditation, certification, and use of a recovery capital assessment. We ask the department to state in the chapter, or in guidance issued with it, whether a conditionally certified residence may receive state bed funding, and on what terms. New houses in the months before full accreditation are exactly the beds the Commonwealth says it wants, and the current silence makes them impossible to budget.

7. Address medical cannabis in one place

The draft requires a policy on marijuana consistent with the Medical Cannabis Program. Residences must be drug-free by statute, and some residents hold valid written certifications. We ask the department to publish model language that reconciles the two, including whether a residence may require storage off site and how a residence declines an applicant without running into fair housing exposure. This is the single question new operators ask counsel about most, and one model paragraph would settle it statewide.

8. Publish a compliance checklist and name one point of contact

Much of this chapter will be met by operators with no compliance staff. A one-page checklist in the order the chapter reads, the required postings listed in one place, and a named contact in the Office of Recovery Services would raise compliance more than any additional requirement in the draft.

One more, on the community liaison

We support requiring a designated community liaison. We ask that the chapter state what the liaison must be able to do, such as receive and log neighbor complaints, acknowledge them within one business day, and provide a posted phone number. Our own policies already work this way, and it is the least expensive thing an operator can do to keep a house welcome on its block.

Thank you for the opportunity to comment, and for building a floor under this field before it grows.

Sho-Don Gilliam, Founder

Better Men of Virginia, Inc. · Petersburg, Virginia · (804) 790-9169