The latest version of proposed DBHDS is too broad and unnecessarily places onerous and unnecessary tax payer funded burdens to over-regulate Oxford House Inc. recovery residences.  Oxford Houses operate in 46 states as peer based long-term recovery residences that are affordable and thereby self-sustaining. There is no stated requirement for paid staff to manage individual house affairs nor does the existing model for certification to operate need to be significantly revised.  Oxford Houses of Virginia should be keep separate and distinct from commercial enterprises that operate recovery residences.  The Virginia taxpayers do not need these changes as currently drafted, nor does the Commonwealth need to create a potential recovery crisis with thousands of citizens facing a shortage of affordable living accommodations as they individually address their health and recovery efforts.  

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