I represent a group of professionals who have serious concerns about the Vanguard Landing model and whether it provides individuals with intellectual and developmental disabilities (I/DD) the choice, autonomy, affordability, and community integration required under Home and Community-Based Services (HCBS) standards.
We support the concept of quality community-based housing and strongly believe individuals with I/DD should have meaningful choices about where and with whom they live. Our concern is that the Vanguard Landing model, as currently structured, may create a provider-controlled and financially exclusive environment rather than a true home of choice.
The monthly rent and care-related costs appear to exceed what many individuals receiving SSI/SSDI could reasonably afford, even when certain services may become Medicaid-billable. This raises serious concerns that access is effectively dependent upon parents or families having substantial financial resources.
We are also concerned about the encouragement of wills, trusts, trusteeships, gifts, and other estate-planning arrangements to sustain participation in this model. Families have every right to make their own financial decisions, but providers should not create an expectation that substantial private wealth is necessary to secure a loved one's future.
Similarly, the use and representation of endowment funds warrants scrutiny. Families should not be led to believe that an endowment or private financial commitment guarantees lifetime housing or services when the provider cannot actually guarantee those supports.
We also believe the organization's financial structure—including compensation involving family members —should be transparent and carefully reviewed for potential conflicts of interest and financial incentives. A founder and family make wish to consider taking a backseat in leadership decisions if this is truly a nonprofit model.
We question whether placing individuals with disabilities and their relatives (the proposed non-disabled community members) together on one campus constitutes genuine community integration. The presence of family members does not, by itself, create an integrated community. It may instead create a controlled environment in which residents' social relationships and surroundings are largely predetermined.
Individuals with I/DD should have the opportunity to build their own lives, relationships, friendships, and identities within the broader community.
We are particularly concerned about Vanguard Landing's stated requirement that each home be single-gender, with an exception for legally married couples. This appears to restrict an individual's choice of roommate or partner based on gender and marital status.
Unmarried adults without disabilities are generally free to live together. Individuals with I/DD should not lose that same choice simply because they receive HCBS. Requiring legal marriage may also create additional consequences for public benefits and therefore warrants specific review under HCBS requirements concerning autonomy, privacy, relationships, and residential choice.
We are concerned that families are being encouraged to pursue DD Waiver slots specifically in connection with Vanguard Landing and, in some cases, to relocate from other states or communities without any guarantee that a Waiver slot will be available or that the proposed services will ultimately be Medicaid-funded.
Given the limited availability of DD Waiver slots—and the absence of unlimited new slots—families should not be encouraged to relocate, sell homes, or make substantial financial commitments based on the expectation of services that cannot be guaranteed.
This is particularly concerning when families of individuals with I/DD are understandably willing to pay almost anything to secure their loved one's future.
We are also concerned about the organization's existing licensing and compliance history, including reported issues involving medications, staff training and supervision, and incident management. These concerns warrant careful review before expansion of services or Medicaid billing.
Additionally, Vanguard Landing describes its intended population as individuals with “mild to moderate” disabilities. This raises important questions about whether the model is designed to support individuals whose needs become more complex over time.
A person's support needs can change. A true home should not become unavailable simply because an individual's disability becomes more significant or costly to support. We have not seen a clear plan demonstrating how Vanguard Landing will accommodate residents with increased medical, behavioral, or support needs.
We are concerned about reported restrictions on residents' ability to cook and eat in their own homes and about their limited control over meals, community activities, and other aspects of daily life. We also question any additional charges associated with ordinary use of one's own home, including restroom access, which have occurred under their private pay structure.
These are not minor issues. A home should provide privacy, dignity, and control over everyday life. If a provider controls what residents eat, whether they can cook, what activities they participate in, or how they use their own living space, then we must ask whether this is truly a home of choice or a highly structured service setting.
Finally, we question the structure of the development itself. If there are 128 residential spots, why are only two homes designated for “non-billable” individuals?
Why create a large centralized campus rather than smaller, independently managed homes integrated throughout existing neighborhoods?
Mixed-use and mixed-income housing could provide individuals with I/DD genuine opportunities to live alongside people without disabilities rather than concentrating residents within a provider-controlled environment.
We are concerned that a model presented as nonprofit and community-focused may nevertheless be structured around financial sustainability, billable services, and salaries associated with the organization, while placing substantial financial responsibility on families.
We support DMAS's position that this model does not currently meet HCBS standards, and we believe that determination warrants continued scrutiny.
Our concern is not whether individuals with I/DD deserve quality housing—they absolutely do. Our concern is whether they should have to surrender choice, privacy, relationships, financial security, and control over their daily lives in exchange for access to it.
People with I/DD are adults. They deserve to choose where they live, who they live with, what they eat, how they spend their time, who they have relationships with, and how they participate in their communities.
This should be a home of choice—not a provider-controlled environment made financially accessible only to families who can afford it.
We believe individuals with I/DD deserve to be treated as adults and as full members of our communities, with the same dignity, autonomy, and opportunities afforded to everyone else. We appreciate all housing models but wish to hold them to the same standard and accountability process. Vanguard Landing does not yet meet HCBS criteria.